iOS 27.2's expanded ATT prompt is mandatory in five EU countries — what actually changes for your app

Posted on Oct 27 • Originally published at hhfa008.github.io

If your app is distributed in France, Germany, Italy, Poland, or Romania, the App Tracking Transparency prompt your users see is changing — and the old one is no longer an option. Starting with iOS 27.2 and iPadOS 27.2, Apple requires the alternative expanded ATT prompt in those five countries; elsewhere in the EU it is optional, and outside the EU it has no effect.

That is the entire scope. Everything else here is what Apple published, what it did not publish, or a check you can run.

Apple's developer news post, dated September 16, 2026, states the rule in one sentence:

Beginning with iOS 27.2 and iPadOS 27.2, developers will have the option to use an alternative version of the App Tracking Transparency system prompt in the EU. Due to legal requirements, only the alternative version of the system prompt is available for apps distributed in Germany, France, Italy, Poland, and Romania.

The iOS & iPadOS 27.2 RC release notes say the same thing in API language:

AppTrackingTransparency (ATT) now supports an alternative expanded prompt and re-prompting on a yearly basis for EU users. The alternative prompt is required for users in France, Germany, Italy, Poland, and Romania.

One line in the news post is easy to skip: "The requirements for when you must seek permission to track users will remain the same." This is a change to presentation and timing, not to what counts as tracking.

The new call is requestTrackingAuthorization(preferExpandedInterface:additionalInformationAction:completionHandler:). Apple keys the behaviour to two conditions at once: device location and the country or region on the signed-in Apple Account:

Both conditions matter. The API page says the feature "requires the device to be located in a specific European Union country and signed in with an Apple Account with a specific EU country or region." Apple's news post frames the mandate by where the app is distributed; the API page frames runtime behaviour by device and account. Treat all three as separate gates.

The prompt is also skipped entirely in the documented edge cases: tracking is restricted, the global setting is off, another request is already in flight, the call comes from an app extension, or the app is not active. Those paths return immediately.

Most posts quietly invent requirements here. The two Apple pages reviewed do not answer these questions:

1. What the UI must contain. The news post says "modified formatting and language"; the API page says full-page sheet with an optional button. Neither page states a character limit, a required layout, a button order, a button count, or whether a skip control is allowed. If your designer asks for the exact spec, the accurate answer is that Apple has not published one. Screenshots in blog posts are examples, not requirements.

2. Whether the attribution chain changes. I read both pages for mentions of SKAdNetwork and AdAttributionKit. There are none. The release note does not say attribution changes, and it does not say it stays the same. Do not rewrite your attribution integration because of this note. If an SDK initialisation reads ATT status, the only change justified by the published text is handling the new "viewed but unanswered" path.

3. Whether App Review will reject the old call in the five countries. Apple's pages do not say that continuing to call the old method causes a rejection. They also do not say the system silently substitutes the expanded sheet when you call the old method. Both outcomes are unknown. Ship the new call and verify it on a real device; do not treat review behaviour as a compliance strategy.

Everything above is limited to Apple's September 16 post and the 27.2 RC notes. If a number or rule is not in those pages, do not rely on it yet.

The developer-side change Apple has actually documented comes down to three moves: call the new method, add the localized Markdown key, and make.notDetermined retryable. That is enough to be correct in the five countries and optional everywhere else in the EU.

The rest — final copy, layout, review outcomes, and attribution effects — is either a product decision or not yet published. Treat anything more specific than that as unconfirmed until Apple updates the documentation.

More iOS release breakdowns and shipping checklists: https://hhfa008.github.io/personal/cases.html