Throughout the year, our policy team submits filings with government bodies worldwide to advocate for a regulatory environment that inspires and rewards innovation. From issues around regulating artificial intelligence to digital trade, our team is ACTive on a wide range of topics that could have a positive or negative impact on our small business members driving the app economy. Below is a roundup of our filings from around the globe this past month.
Entity: CFPB
Jurisdiction: United States
Summary: The App Association provided input to the Consumer Financial Protection Bureau (CFPB) in response to its request for comments on its proposed rule limiting certain practices by data brokers. The comments are generally supportive of the efforts of the CFPB to understand new business models that sell consumer data to exercise enforcement. The lack of transparency of data broker practices makes users more vulnerable and makes it harder for policymakers to address the problems. The App Association pointed to the lack of a federal privacy law, allowing for a legal gray area that should be defined.
Filed: April 2, 2025
Entity: European Parliament
Jurisdiction: European Union
Summary: The App Association provided feedback on the draft report on the implementation and streamlining of EU internal market rules to strengthen the single market. First The App Association argued that the increased number of regulations in nascent markets has been challenging for small and medium-sized enterprises, specifically noting that in the AI space, there have been more uncertainties under new AI rules in the EU. The App Association advocated for clear frameworks and flexibility that allows for scaling in these fast-moving digital markets.
Filed: April 4, 2025
Entity: CFPB
Jurisdiction: United States
Summary: The App Association provides input to the Consumer Financial Protection Bureau (CFPB) in response to its request for information regarding the collection, use, and monetization of consumer payments and other personal financial data. The App Association argued that any new requirements should be based on risks to consumers and provide consumers with the knowledge of risks associated with non-banking third-party financial companies.
Filed: April 11, 2025
Entity: AGCOM (Italy)
Jurisdiction: Italy
Summary: The App Association submitted comments to the Italian Communication Agency on including Content Delivery Network providers or Content and Application Providers into the European Electronic Communications Code. The App Association is strongly supportive of the development of advanced electronic communication networks and technological innovations. The comments urged Agcom to ensure that its efforts in this matter do not undermine or conflict with other related European Union and/or national goals and priorities.
Filed: April 14, 2025
Title: ACT | The App Association’s Amicus Brief Re: Doe v. Github
Entity: 9th Circuit Court of Appeals
Jurisdiction: United States
Summary: The App Association filed an amicus brief in Doe v. GitHub, arguing that the court’s application of the Digital Millennium Copyright Act (DMCA) hurts Generative AI platforms that can pull data from the public domain and licensed datasets to train without human instruction. The brief urges the court to consider the case of the open-source model and its impact on U.S. economic and national security in rejecting a rigid identicality requirement for a §1202(b) claim under the DMCA.
Filed: April 16, 2025
Entity: ACCC
Jurisdiction: Australia
Summary: The App Association provided input to the Australian Competition and Consumer Commission (ACCC) as it finalizes its Draft Merger Assessment Guidelines. The App Association emphasized the following principles in the creation of this new draft: predictable changes in legal environment, rigorous economic analysis of any new changes, and data-driven harm as evidence for new changes.
Filed: April 17, 2025
Entity: DG COMP
Jurisdiction: European Union
Summary: The App Associations submitted comments regarding the update to the Technical Transfer Block Exemption Regulation (TTBER) and associated guidelines for the European Commission. Emphasizing the critical role of fair, reasonable, and non-discriminatory licensing of standard-essential patents in fostering innovation, particularly within the Internet of Things (IoT) sector. The comments include recommendations that aim to ensure that the TTBER continues to promote a competitive and innovative environment for small and medium-sized enterprises in the evolving digital economy.
Filed: April 25, 2025
Title: ACT | The App Association’s Reply for the AI Literacy Survey to the European Commission
Entity: EU AI Office
Jurisdiction: European Union
Summary: The App Association completed an AI literacy survey for the European Commission. The response emphasized the App Association’s development of AI literacy training materials and policies.
Filed: April 29, 2025