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Switzerland is examining whether Apple’s rules for third-party access to iPhone contactless-payment technology allow real competition with Apple Pay. The Competition Commission’s Secretariat (COMCO, or WEKO in German) opened a preliminary investigation on December 10, 2025. Swiss providers already have access to Apple’s NFC & SE platform, according to COMCO; the unresolved question is whether the terms make that access effective and comply with Swiss competition law.
What COMCO is investigating
COMCO announced the investigation on December 11, 2025. It is gathering information about Apple’s terms for third parties to access NFC functionality on iOS devices and whether rival mobile-payment apps can effectively compete with Apple Pay for contactless payments in Swiss shops. This is a preliminary investigation, not a final finding that Apple broke the law, a fine, or an order to change its system. COMCO’s announcement says Apple has allowed Swiss third-party app providers to use its NFC & SE platform since the end of 2024.
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That distinction matters: the case is not about whether any Swiss third party can access iPhone NFC at all. It is about whether the conditions of access—and the practical capabilities they provide—are sufficient for competitors to challenge Apple Pay.
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NFC, or near-field communication, is the short-range wireless technology that lets a phone communicate with a contactless payment terminal. But an NFC chip alone does not make an iPhone a usable payment terminal companion. A wallet also needs the software pathway to initiate a transaction, authenticate the user, and work with protected payment credentials stored or handled through the phone’s secure architecture.
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Apple controls the iOS interfaces involved in that process, including access to NFC and secure-element functionality. That control can support security and consistent performance, but it also gives Apple influence over which wallets can offer an iPhone tap-to-pay experience and on what terms. The competition question is therefore broader than whether an app can technically detect an NFC terminal: it concerns the interfaces, authentication, system behavior and commercial conditions needed to provide a dependable payment service.
COMCO says that until 2024 Apple denied third-party providers access to the iPhone NFC interface, while comparable access was freely available on Android. In that period Apple Pay was the principal route for contactless mobile-wallet payments on iPhones. This is specifically about in-store contactless payments, not every kind of payment. Web checkout, in-app payments and QR-code transactions are different functions and could still be offered by other apps.
How the Swiss arrangement differs from the EU
The European Commission’s Apple Pay proceeding resulted in legally binding commitments accepted on July 11, 2024. Under the EU/EEA framework, eligible third-party wallet and payment-service providers must receive free access to and interoperability with iOS NFC, without having to use Apple Pay or Apple Wallet. The commitments were a negotiated resolution of that part of the proceeding—not a fine or a final ruling that Apple had infringed competition law. The Commission’s earlier statement of objections was a preliminary assessment, not a final judgment. The commitments are published in EUR-Lex.
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COMCO says it began discussions with Apple in spring 2024 and that Swiss third-party providers gained access through NFC & SE by the end of that year. It also says the Swiss arrangement differs from the EU/EEA solution, which is why it is testing the Swiss terms under Swiss law. The public Swiss materials do not provide a complete side-by-side account of the differences. They do not establish, for example, whether the arrangements differ in fees or other costs, eligibility, liability, authentication, default-wallet behavior, technical capabilities, or Apple’s power to suspend access. Those details should not be assumed; they are among the practical matters relevant to assessing whether access is meaningful.
What “effective competition” would look like in practice
Formal permission to connect to an interface does not necessarily put a rival wallet on equal footing. To assess whether a provider can compete in practice, COMCO may need to examine questions such as:
- Can a rival wallet initiate a tap-to-pay transaction conveniently, including from the lock screen, and can users choose it as their preferred wallet?
- Does it work with the phone locked and support authentication through Face ID, Touch ID or a passcode?
- Does it have the secure-element functions and card setup options needed for reliable payments?
- Are the technical requirements, certification process and version support clear, consistent and workable for providers at scale?
- Do the terms make the service commercially viable, and can Apple change or revoke access on terms that are predictable and reviewable?
- Do interface prompts, defaults or automatic wallet activation give Apple Pay a practical advantage even when a rival has NFC access?
These are questions for investigation, not findings established in the public record. Security requirements can be legitimate, especially for payment credentials, but their rationale and application matter: a requirement that protects users is different from one that unnecessarily disadvantages competing providers. A meaningful remedy, if one is warranted, would have to address more than an API’s existence—it would need workable technical access, fair treatment, user choice and durable rules.
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Which rivals could be affected?
Potentially relevant providers include Swiss mobile-payment services such as TWINT, bank- or fintech-operated wallets, card issuer or network apps, and international wallet providers. Their inclusion as possible competitors does not mean they currently offer equivalent iPhone NFC payments in Switzerland. Each would need compatible service features, issuer or bank support, and access under Apple’s rules. Some merchant, transit or ticketing apps may also need contactless credentials without trying to be general-purpose payment wallets.
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Even if access improves, a Swiss iPhone user would not automatically gain a new wallet choice. A provider must launch or support its service in Switzerland; the user’s bank or card issuer must participate; the iPhone and iOS version must be compatible; and the merchant’s terminal must accept the relevant payment credential or network. NFC access also does not guarantee that a wallet supports transit, loyalty or access-control credentials.
Do not confuse this with Switzerland’s earlier mobile-payment cases
The 2025 proceeding is distinct from a 2018 Swiss investigation into whether financial institutions had boycotted international mobile-payment services such as Apple Pay and Samsung Pay. That inquiry concerned possible exclusion by banks and other financial institutions; the current one concerns Apple’s terms for access to iPhone NFC. The Swiss government’s 2018 announcement describes the earlier case.
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| Proceeding | Conduct examined | Entity at issue |
|---|---|---|
| 2018 Swiss investigation | Suspected boycott or exclusion of international mobile-payment services | Swiss financial institutions |
| 2025 Swiss NFC investigation | Terms and practical conditions for third-party access to iPhone NFC | Apple |
There is also separate Swiss context involving TWINT and Apple. COMCO materials describe an earlier technical issue in which Apple Pay could activate automatically at payment terminals and interfere with TWINT’s payment flow; Apple agreed to provide TWINT with a suppression code. That episode is not the 2025 NFC investigation, but it illustrates why default behavior and the way a wallet is invoked can affect competition even when the underlying payment technology is available. COMCO’s competition-policy report discusses the issue.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Apple’s security rationale and rivals’ access concerns
Payment systems handle sensitive credentials, so Apple can reasonably argue that secure-element access and authentication require careful safeguards. It may also argue that third-party access is already available in Switzerland and that the Swiss technical or legal framework differs from the EEA. These are plausible considerations, not claims about a public Apple response: the reviewed COMCO materials do not set out Apple’s detailed position or the Swiss contractual terms.
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What happens next—and what users should expect
As of August 18, 2026, the latest official material identified for this article still describes the case as a preliminary investigation. COMCO’s 2025 annual report records the investigation and its scope, but no final finding, fine, settlement or completed remedy. The public materials therefore do not support a prediction about the outcome or timetable.
For users and businesses, the immediate significance is scrutiny of the rules, not an announced change to how iPhone payments work. If COMCO eventually finds that the Swiss conditions prevent effective competition, the practical consequences would depend on its conclusions and any remedy. More choice would still depend on wallets, banks, devices and merchants supporting one another. The central issue remains whether Swiss providers have access that works as well in practice as it does on paper.
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