Awin supports Apple’s mission to protect user privacy, but today we are urging the company to provide clearer guidance for those engaged in affiliate marketing under the App Tracking Transparency (ATT) framework.
The current lack of clarity is unintentionally harming privacy-respecting publishers and content creators.
We call on Apple to take three crucial actions:
Distinguish affiliate measurement from invasive ad tracking.
Confirm that app owners will not be penalized for enabling compliant attribution.
Offer practical guidance that protects user choice while preserving publisher value.
Why ATT represents a problem for the affiliate channel
Apple’s ATT framework, while well-intentioned, is creating ambiguity that undermines publishers, who are vital to a diverse and competitive digital economy.
Unlike large ad tech platforms, affiliate networks like Awin do not build or monetize user profiles, nor do we engage in cross-site retargeting. Our role is simple: we measure ad outcomes in a data-light, privacy-conscious way to ensure publishers are accurately rewarded for the value they drive.
However, ATT currently lacks explicit guidance on whether in-app affiliate measurement is allowed when a user opts out of data sharing with third parties. This binary implementation is a blunt instrument, creating unnecessary harm to the affiliate model and the independent content economy it supports.
Apple is creating its own rulebook
In contrast, regulators such as the UK’s Information Commissioner’s Office (ICO) and France’s Commission Nationale de l’Informatique et des Libertés (CNIL) have taken a more nuanced view.
The ICO has acknowledged that affiliate tracking tied to incentives may be exempt from consent under specific conditions. Meanwhile, CNIL recently clarified that certain audience measurement tools – such as web analytics – can be used without consent when they meet strict criteria, including not cross-tracking users or generating advertising profiles.
This kind of regulatory clarity from Apple in the app space is absent, and the real-world consequences are significant.
AppsFlyer reports that only 40% of users, when prompted, opt in to tracking. That means the majority of iOS users fall into this uncertain zone.
At the same time, research from the IPA shows that UK consumers now spend more time on their phones than watching TV for the first time. This is a tipping point that underlines the importance of getting mobile attribution right.
Retailers, understandably risk-averse, often fear that enabling even limited data sharing, such as sending an order reference or record of an individual sale to an affiliate network for the sole purpose of validating a user action, might breach ATT and result in App Store removal.
This leads to one of two outcomes:
Affiliate activity is not attributed at all for users with a declined ATT status.
It’s attributed without the data required to verify and reward that activity accurately, meaning publishers lose out.
Both scenarios create misattribution, underpayment and uncertainty, not only for publishers but also for users expecting the experience they already opted in to.
We have the tools, but not the guidance
There are technical solutions available today through Mobile Measurement Partners (MMPs) that could support compliant, privacy-safe attribution. However, these tools remain underutilized and non-standard because of the absence of clear guidance.
Greater guidance from Apple would unlock their use and help prevent affiliate sales from being wrongly credited to the dominant platforms ATT was designed to check.
Apple’s binary approach also fails to reflect what users want. It seems self-evident that a user clicking on a cashback offer on an iOS device expects to receive that cashback. That expectation can be met but often isn’t because of the ambiguity of ATT. This harms the very consumers Apple aims to protect.
We do not believe Apple intended to target the affiliate industry. But the impact is clear.
Awin urges Apple to engage directly with affiliate networks, publishers, and relevant regulators to provide clarity that protects user rights whilst allowing for the content that inspired them to be recognized. The affiliate channel can and should be a model for ethical performance advertising – Apple now has the opportunity to recognize that.
Paul Stewart
Group Strategic Partnerships Director, Awin
