A message from our founder on the Digital Fairness Act

Building for Europe and Facing Its Growing Contradictions

As I write this from our offices in the Netherlands, I’m watching new regulation being proposed by the European Commission that impacts our industry. In the last few years the regulatory framework in Europe has become so complex that it could rival legislation on in healthcare or in defense industries.

All this while we are talking about apps and digital marketing. Yes, apps. Innovative apps. Apps that help Europeans move, learn, and innovate the very freedoms the European Union was built to enable.

Our products mEUvy for talent mobility, EUnify for education mobility, and EUorigin for innovation mobility represent exactly the kind of digital innovation the EU claims to champion. Yet with each new wave of legislation, it’s becoming increasingly difficult for small companies like ours to keep building in Europe.

The proposed Digital Fairness Act (DFA) is the latest addition to a rapidly expanding stack of overlapping rules from the Digital Markets Act (DMA) to the AI Act that, while well-intentioned, risk creating a maze so complex that only the largest global corporations can afford to comply.

Apple input — and Why It Matters

Apple recently submitted its official response to the European Commission’s Call for Evidence on the Digital Fairness Act. In its document, “Empowering Users in the Digital Economy”, Apple welcomes many of the DFA’s goals stronger transparency, user empowerment, and better child safety but also warns that a lack of coordination between EU regulations could “exacerbate risks for consumers rather than reduce them.”

Apple highlights a growing concern that has become familiar to all of us developing in Europe: regulatory contradictions that unintentionally harm both user privacy and innovation.

As Apple explains, the DMA has already required it to “decrypt notifications on user devices and share them with third parties” and to “share users’ full Wi-Fi history,” creating potential vectors for surveillance and data misuse. Apple cautions that such obligations “set a precedent for companies to request even more data in ways that undermine the GDPR’s data-minimization principles — putting EU users at much higher risk of tracking.”

This isn’t an argument against regulation. It’s a call for coherence. As Apple notes, unintended consequences arise “when legislation is enacted without a full assessment of its impact on consumers.”

Privacy by Design — A Shared Foundation

Apple’s submission reminds us that privacy isn’t an obstacle to innovation it’s the foundation for it. The company describes privacy as “a fundamental human right,” built into every Apple product through four principles: data minimization, on-device processing, user transparency and control, and security.

Those principles aren’t theoretical; they’re practical safeguards that enable responsible developers like us to create trustworthy technology. Apple’s App Tracking Transparency (ATT) framework, for instance, has been recognized by the European Commission as “user-friendly and empowering”, allowing millions of Europeans to control how their data is shared.

At vaic.at, our entire business model is built on those same principles. Our apps rely on Apple’s privacy frameworks not just to comply with regulation, but to earn user trust. Features like on-device processing and App Store integrity make it possible for us to operate without harvesting or selling data. Weakening these frameworks, as current policy trends risk doing, would make our services and the business model that sustains them unviable in the EU. After more than a decade building for this market, that’s not a scenario we ever thought we’d have to consider.

The Broader Problem — A Patchwork Without Coherence

Europe’s current regulatory environment suffers from fragmentation. The GDPR tells us to minimize data collection. The DMA forces platforms to share more data. The DFA now proposes new “fairness” layers without resolving those contradictions.

Apple’s submission calls for a change in approach one focused on consistency, collaboration, and practical outcomes. The company urges the EU to:

Promote privacy-preserving innovation, by “incentivizing technologies like homomorphic encryption and differential privacy.” Define dark patterns precisely, to prevent manipulation while protecting legitimate privacy features. Digitize consumer information, reducing environmental waste — Apple notes it still bundles nearly “one billion sheets of regulatory paper with its products in Europe each year.” Strengthen cooperation among regulators, ensuring that competition, privacy, and security authorities don’t work at cross-purposes.

This is the kind of balanced, forward-looking reform Europe needs. We aren’t asking for less oversight it’s asking for smarter oversight.

The Human Cost of Misalignment

The App Store ecosystem supports 1.7 million jobs across Europe. Each of those jobs represents a developer, designer, or entrepreneur building something new and each new regulatory contradiction puts that ecosystem under pressure.

For small teams, the cost of compliance can be crushing. What used to be a €100 annual developer fee has become thousands of euros in legal consultations and compliance audits. For many, that’s the difference between building their next product and shutting down.

A Constructive Way Forward

Europe doesn’t need more rules; it needs better alignment. Regulations must reinforce each other, not cancel each other out. They must protect consumers without undermining the very privacy frameworks that make European software trustworthy. And they must recognize that innovation requires room for experimentation not perpetual compliance anxiety.

Apple’s submission closes with a hopeful reminder:

“We support policies that create transparency for users, preserve people’s privacy, keep children safe online, and hold companies accountable for the content on their platforms. We’re hopeful that lawmakers will continue to prioritize these values as the Digital Fairness Act takes shape.”

That hope for balance, for partnership, for coherence is one we share.

We ask Apple to continue to champion its values and help inspire the European Commission to course correct.

A Message to Brussels

Before finalizing the DFA, the European Commission should talk to the people who actually build Europe’s technology. Not just lobbyists or large corporations but the thousands of small teams like ours who experience the impact of every legislative change directly.

We support the goal of fairness. We support accountability. But fairness must also extend to innovators to the small European builders trying to create secure, ethical, and sustainable technology within an increasingly hostile regulatory climate.

Europe’s Choice

Europe still has the opportunity to get this right. The Digital Fairness Act can empower users and protect privacy but only if it aligns with the frameworks that already work, instead of dismantling them.

At vaic.at, we remain committed to building for Europe’s future. Our mission is to make our continent more mobile, more connected, and more innovative. But that future depends on a regulatory environment that strengthens not suffocates the innovators who make it possible.