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.
Title: Comments of ACT | The App Association, Grant Taking: Sensitive personal data – biometric data
Entity: Autoridade Nacional de Proteção de Dados (ANPD)
Jurisdiction: Brazil
Summary: The App Association submitted comments to the ANPD regarding whether there is a need for regulatory intervention with respect to the processing of biometric data. The comments urged ANPD to ensure that its requirements are based on established risks and harms rather than hypothetical or rare situations and discussed in detail two key use cases: facial verification and wearables.
Filed: July 2, 2025
Title: ACT | The App Association comments, Draft rules for digital markets competition regime levy
Entity: Competition and Markets Authority (CMA)
Jurisdiction: United Kingdom
Summary: The App Association provided comments to CMA regarding the agency’s proposed levy for the digital markets competition regime, warning CMA against implementing the levy in a way that could negatively affect the ability of curated online platforms to provide the benefits to small businesses underpinning the competitive nature of today’s app economy.
Filed: July 3, 2025
Entity: Office of the Controller General of Patents, Designs & Trade Marks (CGPDTM)
Jurisdiction: India
Summary: The App Association filed comments in response to the Indian patent and trademark regulator’s proposed updated guidelines for examination of CRIs. The App Association praised CGPDTM’s moves to incentivize patent applications for emerging technologies such as artificial intelligence while urging the Office to develop standard-essential patent (SEP)-specific guidance to avoid the harms to innovation and competition that result when SEPs are not offered on fair, reasonable, and non-discriminatory (FRAND) terms.
Filed: July 7, 2025
Title: Feedback of ACT | The App Association to the European Commission regarding its Digital Networks Act
Entity: European Commission
Jurisdiction: European Union
Summary: The App Association submitted comments to the European Commission in response to its consultation on the upcoming Digital Networks Act. The comments urged the Commission to continue efforts to simplify and harmonize the EU’s regulatory landscape, opposed mandated dispute resolution mechanisms, described how the Commission could better preserve the balance between large and small entities, and stressed the importance of transparency, stakeholder inclusivity, and small business representation in any enhanced EU governance.
Filed: July 11, 2025
Title: Comments of ACT | The App Association on the Draft 2025 United States Standards Strategy
Entity: American National Standards Institute (ANSI)
Jurisdiction: United States
Summary: The App Association submitted comments to ANSI regarding its proposed draft of the United States Standards Strategy (USSS). The comments argued that the USSS should make the case for standards in the marketplace, augment efforts that track standards development activities, support small business participation in standards development, resolve uncertainties regarding ANSI-accredited organizations, and mitigate barriers to the use of standards. The comments further urged that the USSS should affirm private-sector leadership as the foundation of the U.S. standards system, expand support for small business participation, establish clear channels for public-private coordination, and enable ANSI to address SEP licensing abuse.
Filed: July 14, 2025
Entity: National Science Foundation
Jurisdiction: United States
Summary: The App Association submitted comments to NSF in response to its request for information to assist in its update of its Key Technology Focus Areas. The comments included the App Association’s comprehensive AI policy principles, which cover issues including harmonizing and coordinating approaches to AI, quality assurance and oversight, data bias, privacy and security, and intellectual property.
Filed: July 21, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: The App Association provided feedback to the Commission on its proposed revisions to the Regulation on standardization. The comments argued that the Commission should make the case for standards in the marketplace, augment efforts that track standards development activities, support small business participation in standards development, resolve uncertainties regarding Commission-overseen organizations, and mitigate barriers to the use of standards. The App Association urged the Commission to use the opportunity of revising the Regulation to strengthen the European standardization system’s ability to generate solutions from the bottom up via the consensus of the private sector, civil society, and technical stakeholders.
Filed: July 21, 2025