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: Unified Patent Court
Jurisdiction: European Union (EU)
Summary: The App Association submitted comments to the EU’s Unified Patent Court in response to proposed updates to its arbitration rules. The comments recommended that the rules make clear that non-participation in arbitration should not be used as an indication that one party is acting as an “unwilling” party, provide parameters regarding appropriate fair, reasonable, and non-discriminatory (FRAND) rate methodology, and increase transparency of important arbitration decisions.
Filed: 4 August 2025
Entity: Canadian Competition Bureau
Jurisdiction: Canada
Summary: The App Association filed comments in response to the Canadian Competition Bureau’s discussion paper on algorithmic pricing and competition. The comments argued that under certain circumstances, algorithmic pricing can be pro-competitive and that policies should be industry-agnostic and evidence-driven rather than prescriptive, sector-specific, or inflexible.
Filed: 4 August 2025
Entity: Office of the Privacy Commissioner of Canada (OPC)
Jurisdiction: Canada
Summary: The App Association filed comments to OPC in response to its exploratory consultation on the development of a Children’s Privacy Code. The comments warned against age assurance requirements that are too technologically prescriptive and make the applicability of a design code too vague.
Filed: 5 August 2025
Title: Comments of ACT | The App Association Regarding the Draft National Telecom Policy 2025
Entity: Department of Telecommunications
Jurisdiction: India
Summary: The App Association filed comments in response to the Department of Telecommunications’ request for feedback on its Consultation Paper on Encouraging R&D in Telecom, Broadcasting, and IT Sectors. The comments made a number of recommendations in areas including promoting the development of domestic startups, alignment with international standards, taking a balanced approach to spectrum policy, and avoiding universal service obligations for over-the-top (OTT) providers.
Filed: 14 August 2025
Entity: National Oceanic and Atmospheric Administration (NOAA) and the Department of State
Jurisdiction: United States
Summary: The App Association provided comments to NOAA’s Office of Space Commerce and the State Department’s Office of Space Affairs in response to their joint request for comment on the European Union’s Space Act and Vision for a European Space Economy publication. The comments urged NOAA and the State Department to encourage the EU to ensure that any space regulatory requirements are in alignment with international standards and U.S. regulations, to ensure its regulations do not create unnecessary barriers to competition and innovation, to employ technology-neutral rules, and to avoid fostering a culture of compliance over regulation.
Filed: 14 August 2025
Entity: United States Trade Representative (USTR)
Jurisdiction: United States
Summary: The App Association submitted comments to USTR in response to its initiation of a Section 301 investigation into acts and practices affecting trade by Brazil. The comments highlighted ways in which certain of Brazil’s policies function as digital trade barriers affecting small businesses, including Brazil’s general data protection law, proposed competition regulation frameworks, advancing regulation of AI, consideration of OTT regulatory requirements, and discriminatory localization policies.
Filed: 18 Aug 2025
Entity: Department of Education
Jurisdiction: United States
Summary: The App Association filed comments in response to the Secretary of Education’s proposal to make artificial intelligence a priority in grantmaking. The comments included the App Association’s comprehensive AI policy principles, including harmonizing and coordinating approaches to AI, mitigating issues related to data bias, supporting education, and protecting intellectual property.
Filed: 20 August 2025
Entity: Global Affairs Canada
Jurisdiction: Canada
Summary: The App Association provided comments to Global Affairs Canada to inform Canada’s exploratory discussions for a digital trade agreement with the European Union. The App Association included its digital trade principles and made specific recommendations including prohibiting digital customs duties, ensuring cross-border data flows, discouraging the misapplication of competition laws, and furthering harmonized reliance on international technical standards.
Filed: 25 August 2025
Entity: European Commission
Jurisdiction: European Union
Summary: The App Association submitted comments to the European Commission’s consultation on the revision of Regulations to simplify legal obligations and improve the environment for small and medium-sized enterprises (SMEs). While supporting the Commission’s overall efforts, the App Association made specific recommendations regarding the treatment of SMEs under the General Data Protection Regulation, the Digital Markets Act, the Data Act, the AI Act, and others.
Filed: 25 August 2025