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 on the Proposed Rule Implementing the New Jersey Data Privacy Act

Entity: New Jersey Division of Consumer Affairs

Jurisdiction: New Jersey, United States

Summary: The App Association provided detailed recommendations on the proposed rule implementing New Jersey’s new data privacy law, urging regulators to adopt consumer privacy protection provisions that are clear, interoperable with other U.S. state and federal laws, and do not impose disproportionate compliance obligations on small businesses.

Filed: September 2, 2025

Title: Feedback of ACT | The App Association to the European Commission regarding its Merger Guidelines

Entity: European Commission

Jurisdiction: European Union

Summary: The App Association provided feedback in response to the European Commission’s consultation on the revision of the Union’s merger guidelines, urging caution to ensure that merger interventions are evidence-based and proportionate to the actual risks posed by a given merger. The App Association encouraged the Commission to continue refining its guidelines with the goal of fostering, rather than unintentionally stifling, entrepreneurial activity.

Filed: September 3, 2025

Title: Submission of ACT | The App Association re: Inquiry into Human Rights and the Regulation of AI

Entity: Joint Committee on Human Rights, Houses of Parliament

Jurisdiction: United Kingdom

Summary: The App Association submitted views to the UK Parliament’s Joint Committee on Human Rights in response to its inquiry into human rights and the regulation of artificial intelligence (AI). The comments incorporated the App Associations comprehensive AI policy principles, including harmonizing and coordinating approaches to AI, modernizing privacy and security frameworks, and protecting intellectual property rights.

Filed: September 5, 2025

Title: ACT | The App Association Comments Regarding the Taiwan Fair Trade Commission’s Request for Comments Concerning Consultation Paper on Generative Artificial Intelligence and Competition

Entity: Taiwan Fair Trade Commission

Jurisdiction: Taiwan

Summary: The App Association submitted comments to the Taiwan Fair Trade Commission in response to its consultation paper on the effects of generative AI on competition. The comments incorporated the App Association’s comprehensive AI policy principles, as well as arguing against assertions that AI marketplaces are more prone to competition problems than others and for the proposition that large platforms can provide small businesses with important advantages.

Filed: September 8, 2025

 

Title: ACT | The App Association Comments to the Malaysia Competition Commission for Market Review on the Digital Economy Ecosystem Under the Competition Act 2010

Entity: Malaysia Competition Commission (MyCC)

Jurisdiction: Malaysia

Summary: The App Association submitted comments to MyCC in response to its public consultation on its draft final report for market review on the digital economy ecosystem. The comments included the App Association’s paper on competition in the digital economy and expressed concerns that MyCC’s findings did not accurately reflect the competitive nature of the app ecosystem.

Filed: September 14, 2025

 Title: Comments of ACT | The App Association in response to the Department of Justice Antitrust Division Request for Information on State Laws Having Significant Adverse Effects on the National Economy or Significant Adverse Effects on Interstate Commerce

Entity: Department of Justice

Jurisdiction: United States

Summary: The App Association submitted comments to the Justice Department highlighting state laws that have negative effects on the participation of small businesses in the digital economy, including unintended consequences of privacy laws in Illinois and California and children’s online safety laws in Utah, Texas, and Louisiana.

Filed: September 15, 2025

Title: Feedback of ACT | The App Association to the European Commission regarding the Review of the Digital Markets Act

Entity: European Commission

Jurisdiction: European Union

Summary: The App Association submitted comments to the European Commission as part of its consultation on the review of the Digital Markets Act (DMA). The comments urged the Commission to consider the important benefits that platforms designated as “gatekeepers” have for small and medium sized enterprises and provided specific suggestions on how various areas of the law could be improved.

Filed: September 23, 2025

Title: ACT | The App Association’s Response to the European Commission regarding the Consultation on AI in the Context of DMA Review

Entity: European Commission

Jurisdiction: European Union

Summary: The App Association responded to the European Commission’s consultation on AI in the context of DMA review. The response argued against designating AI itself as a Core Platform Service (CPS) under the Act, as AI is not a standalone service but a general-purpose technology. Designating AI as a CPS would harm small businesses by raising costs and reducing access to an increasingly important tool.

Filed: September 24, 2025

Title: Input of ACT | The App Association regarding the U.S. Trade Representative’s Request for Comments Concerning China’s Compliance with WTO Commitments

Entity: United States Trade Representative (USTR)

Jurisdiction: United States

Summary: The App Association responded to USTR’s request for comments on China’s compliance with its commitments as part of the World Trade Organization (WTO). The comments included the App Association’s general digital trade principles, as well as specific discussion of the impacts on small businesses of China’s intellectual property, antitrust, encryption, cybersecurity, and privacy laws.

Filed: September 24, 2025

 

Title: Comments of ACT | The App Association to the Singapore Ministry of Law on its 2025 Public Consultation on Guide for Using Generative Artificial Intelligence in the Legal Sector

Entity: Ministry of Law, Legal Technology Transformation Office

Jurisdiction: Singapore

Summary: The App Association filed comments in response to the Singapore Ministry of Law in response to its request for input on their guide for using generative AI in the legal sector. The comments included the App Association’s general AI policy principles, including considerations for roles and responsibilities across the AI value chain, quality assurance, privacy and security, ethics, and intellectual property.

Filed: September 30, 2025

Title: Feedback of ACT | The App Association to the European Commission regarding its 28th Regime – a single harmonized set of rules for innovative companies throughout the EU

Entity: European Commission

Jurisdiction: European Union

Summary: The App Association provided comments to the European Commission in response to its consultation on updates to the 28th regime, a central instrument to simplify company law and provide a single EU corporate compliance framework. The App Association urged the Commission to make the 28th regime a Regulation rather than merely a Directive and discussed the importance of its key pillars, including simplification and digitalization, reducing the cost of corporate failure, attracting finance and investment, and attracting and retaining talent.

Filed: September 30, 2025