---
title: "PESTEL example: UK mobile-platform law and Porter's forces"
description: "One legal factor, one Porter force, one decision: how UK digital-markets law on Apple and Google changes app pricing and launch timing for founders."
url: "https://staging.khoi.co.uk/en/blog/pestel-luat-nen-tang-di-dong"
lang: en-GB
author: "Lê Quốc Khôi"
date: 2026-11-03
updated: 2026-11-03
topics: ["Strategy & leadership"]
tags: ["PESTEL", "Porter's five forces", "UK digital-markets law", "App store fees", "Market entry"]
---

# PESTEL is not a checklist: UK mobile-platform regulation

## Key takeaways

- PESTEL helps only when you pick one factor, prove it decisive with evidence from outside the company, and name the decision that changes; filling all six boxes and stopping is the pitfall the library records.
- On 22 October 2025 the Competition and Markets Authority (CMA) confirmed that Apple and Google have strategic market status (SMS) in mobile platforms, for a period of five years (Competition and Markets Authority, 2025; UK Parliament, 2024, s. 18).
- Designation is not a rulebook: the CMA says it is not a finding of wrongdoing and introduces no immediate requirements (Competition and Markets Authority, 2025). On CMA pages up to 20 October 2026 I found only proposals, on steering and on NFC, and no requirement already imposed.
- On my reading, the event mainly moves supplier power and the threat of entry, two of Porter's forces; the summary of his 2008 article says government policy changes the relative strength of the forces (Porter, 2008).

Suppose you are a founder in Ho Chi Minh City with a payments app, and next quarter you must fix the plan for a UK launch. Your team's PESTEL has six boxes, and the Legal box says "new digital competition law". Does that line change your price, your partners or your launch date? If not, the box has done no work. This post takes [PESTEL](https://staging.khoi.co.uk/en/framework/pestel) down one path: a dated legal event, one Porter force it moves, one decision that changes.

## Does filling in all six PESTEL boxes help you decide anything?

Not if you stop at filling. The site's library names this pitfall under PESTEL: listing all six boxes and stopping, when the value lies in picking one factor and showing why it is decisive, with evidence from outside the company.

> **Figure:** [PESTLE analysis](https://staging.khoi.co.uk/en/framework/pestel) The six PESTEL factors with the Legal box highlighted (redrawn from the library, origin credited to Johnson and others, 2008; Whittington and others, 2023).

To make a factor change a decision, I ask three questions. Does the event have a date and a public source? Which of the [five competitive forces](https://staging.khoi.co.uk/en/framework/porter-five-forces) does it push, and in which direction? Which of my decisions, on price, partners or launch date, changes with it? I put the three together myself; they are not a procedure from the PESTEL authors or from Porter. Choosing the force that takes the most profit already has a worked example in [Porter without a strategy department](https://staging.khoi.co.uk/en/blog/porter-cho-doanh-nghiep-nho); this post goes from an outside event to the force it pushes.

## What has UK digital-markets law done to Apple and Google, and where does it stand?

On 22 October 2025 the Competition and Markets Authority (CMA) confirmed that Apple and Google have strategic market status (SMS) in mobile platforms (Competition and Markets Authority, 2025). That is a designation, not a rulebook. On the CMA pages I read on 3 November 2026, there were proposed rules only.

The basis is the Digital Markets, Competition and Consumers Act 2024. The CMA may designate only after an SMS investigation, when a firm has substantial and entrenched market power and a position of strategic significance in a digital activity linked to the UK (UK Parliament, 2024, s. 2). The turnover condition is above £25 billion globally or above £1 billion in the UK (UK Parliament, 2024, s. 7), so your start-up is a user of these services, not a regulated party. The [designation notice for Apple](https://assets.publishing.service.gov.uk/media/68f8c05f190c6607448bb74a/SMS_decision_notice__Apple_.pdf) gives the period as 23 October 2025 to 22 October 2030 (p. 2).

Conduct requirements are a separate step. The CMA may impose one only if it considers it proportionate for one of three objectives: fair dealing, open choices, or trust and transparency (UK Parliament, 2024, s. 19). The permitted types include obliging a firm to "trade on fair and reasonable terms" and preventing it from using its position to treat its own products more favourably (UK Parliament, 2024, s. 20).

> **Figure:** (steps) Status as of sources read on 3 November 2026: the Apple case page was last updated on 20 October 2026, the Google page on 14 August 2026.

```json
{
  "type": "steps",
  "phases": [
    {
      "label": "Dates published",
      "steps": [
        { "title": "22 Oct 2025: SMS designation", "body": "Apple and Google, mobile platforms. In effect from 23 October 2025 to 22 October 2030." },
        { "title": "10 Feb and 1 Apr 2026: voluntary commitments", "body": "Commitments on app review, ranking and use of data; Apple adds one on requests for interoperable access. Final versions published 1 April 2026. These are not conduct requirements." },
        { "title": "30 Jun 2026: proposals on steering", "body": "One proposal per firm; comments due 28 July 2026, responses published 14 August 2026. The CMA says it will decide later this year." },
        { "title": "20 Oct 2026: proposal on NFC for Apple", "body": "Comments due 17 November 2026; final decision after responses are assessed." },
        { "title": "Not seen: any requirement imposed", "body": "The update lists on the two case pages record no conduct requirement imposed on mobile platforms." }
      ]
    }
  ]
}
```

The CMA draws this line itself. Its [final decision report on Apple](https://assets.publishing.service.gov.uk/media/68fb86f430c331c88be6f0cb/Final_decision_report.pdf) says the SMS finding does not find or assume wrongdoing, and that Parliament separated the assessment for designation from the one for imposing conduct requirements, each under its own legal process (paragraph 1.3, p. 5).

## Which of Porter's forces does the regulation push?

Mainly two: supplier power and the threat of new entrants. That is my reading, because the CMA applies the Act's own tests, not Porter's framework. The industry analysed here is mobile wallets and payments in the UK.

| Porter force | What the sources say | If the proposal is imposed | Status |
|---|---|---|---|
| Supplier power (the platform is the distribution channel and the gate to NFC) | To reach users, businesses must distribute through both platforms (Competition and Markets Authority, 2025). A 30% headline commission on digital content through Apple's in-app billing (report, paragraph 6.102, p. 119). The CMA expects steering fees to be lower than current app-store charges ([30 June 2026 release](https://www.gov.uk/government/news/cma-consults-on-new-requirements-for-apple-and-googles-mobile-platforms)) | Falls | Proposal |
| Threat of new entrants (contactless wallets) | Unlike the EU, no firm has launched a wallet to rival Apple's in the UK. The proposal would make Apple open a further access standard, and the CMA expects access charges to be substantially lower than today (20 October 2026 release, via the [Apple case page](https://www.gov.uk/cma-cases/apples-mobile-platform)) | Barrier falls, threat of entry rises | Proposal, comments to 17 Nov 2026 |
| Existing rivals | Apple both grants access and has its own wallet, the most popular in the UK according to that release. The Act allows rules against favouring one's own products (UK Parliament, 2024, s. 20) | Unclear | No rule yet |

Buyers and substitutes get no row: the sources I read do not say these two forces change.

The same rule cuts both ways. A lower barrier is good news for you, the entrant, but your rivals see the barrier fall too. The summary of Porter's 2008 article says an industry's value can be constrained by the threat of new entrants (Porter, 2008); on my reading, "easier to enter" and "more profitable" are different questions.

## Which founder decisions change?

Price and launch date. Plan the base case on today's rules, and book the benefit of a proposal only when it becomes a rule with a number attached.

### Subscription price: plan on 30% or on a lower rate?

**A hypothetical example**, not data from any business: a UK subscription app has 10,000 people paying £8 a month, or £960,000 a year before tax. The CMA's October 2025 report gives a 30% headline rate and says lower rates apply to the small-business programme and to subscription renewals (paragraph 6.102, p. 119), so replace it with the rate you actually pay. The 20% and 10% rows are my inventions for a sensitivity test; the CMA has set out principles, not a figure.

| Platform's share | Platform keeps per year | You keep per year |
|---|---|---|
| 30% (headline) | £288,000 | £672,000 |
| 20% (assumed) | £192,000 | £768,000 |
| 10% (assumed) | £96,000 | £864,000 |

The gap between 30% and 10% is £192,000, or 20% of revenue (before payment processing and tax): enough to change a plan price or a hiring plan, but only once the rule is real. The approach suits you if most revenue comes from digital content sold inside the app and margins are thin. Keep a web checkout page ready, not switched on. Google has already moved: from 30 June 2026 its new Play Store terms let developers steer users out, with some restrictions (30 June 2026 release). I have not read those terms; until a rule exists, the store's terms are your rules of play.

### Launch date for a wallet: wait for the NFC decision?

Yes, if the product needs NFC, the short-range wireless technology behind tap-to-pay. Comments close on 17 November 2026 and the final decision follows the CMA's assessment of responses, so an NFC-dependent launch date hangs on a decision that does not yet exist.

Build two branches. Branch A launches without NFC and suits you if your core value lies elsewhere, such as spending management. Branch B includes NFC and starts only when the final decision is published and you know how the access fee will be set (the CMA is not proposing to set the price itself); that is your switching indicator ([how to tie an early signal to an action](https://staging.khoi.co.uk/en/blog/lap-kich-ban-cho-chu-doanh-nghiep)). The CMA offers one EU benchmark: six months after Apple agreed to provide NFC access for payments there, Vipps launched the first alternative payment app, followed by PayPal, Klarna, Curve and BBVA. On my reading, that is the EU's lag, not a forecast for the UK.

## When is the Legal factor not the decisive one?

When your decision does not touch what the rule targets. The 30% in the report is about payments for digital content. I did not read any rule for physical goods or services, so if your app sells none, read the app store's terms first.

## Going deeper: where does the framework come from, and what did I read and not read?

The library records PESTEL's origin as Johnson and colleagues (2008) and Whittington and colleagues (2023), two strategy textbooks. I rely only on publication details and the library's description of the pitfall, and did not read either book. For Porter's 2008 article I read the summary and the opening paragraph shown publicly on the Harvard Business Review page, not the full text (Porter, 2008).

On the law and decisions, I read sections 2, 7, 18, 19 and 20 of the Act; four CMA releases (22 October 2025, 10 February 2026, 30 June 2026, 20 October 2026); the programme page and the two case pages; the designation notice for Apple; the summary and context chapters of the Apple report, with paragraphs 6.100 to 6.105. I did not read the Google report, the full consultation documents on steering and NFC, the responses of Apple and Google, the CMA's roadmaps, or the other parts of the Act, so I do not know the exact wording of the proposals.

Three limits. One: pairing PESTEL with Porter is my reading; the CMA uses neither. Two: the direction of each force holds only if a proposal becomes a rule, and neither framework gives magnitude. Three: legal status moves with dates. Everything above holds at the sources I read on 3 November 2026, so reopen the CMA's two case pages before you decide.

## Frequently asked questions

### Does this law apply to my start-up?

Not directly. Only a firm with global turnover above £25 billion or UK turnover above £1 billion can be designated (UK Parliament, 2024, s. 7), so the duties fall on Apple and Google, not on you. The Act has other parts that I did not read, so do not assume that every legal duty of your app in the UK sits here.

### Does a regulator's decision go in the Political or the Legal box?

I put statutes, decisions and formal draft rules under Legal, and government policy under Political. One event often touches both: the CMA's programme page cites the National Payments Vision and the government's industrial strategy when it explains its work on NFC and steering. Recording the date and the source matters more than arguing about the box.

### How often should I update the Legal box?

On the dates the regulator publishes, not on a fixed calendar. In this example the nearest date is the NFC consultation deadline of 17 November 2026, and the CMA says a decision on steering is due later in 2026. Each date is a moment to recheck your assumptions on price and launch.

## References

- Competition and Markets Authority (2025) *CMA confirms Apple and Google have strategic market status in mobile platforms (22 October 2025)*. Available at: https://www.gov.uk/government/news/cma-confirms-apple-and-google-have-strategic-market-status-in-mobile-platforms.
- Porter, M.E. (2008) ‘The five competitive forces that shape strategy’, *Harvard Business Review*, 86(1), pp. 78–93. Available at: https://hbr.org/2008/01/the-five-competitive-forces-that-shape-strategy.
- UK Parliament (2024) *Digital Markets, Competition and Consumers Act 2024*. Available at: https://www.legislation.gov.uk/ukpga/2024/13/contents.

---

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