DMA: Protecting Device Neutrality in Android Devices
The FSFE has submitted its position to the European Commission’s Android interoperability consultation under the Digital Markets Act, calling for, among others, the right to fully uninstall AI-based features from Android devices, and access to interoperability functions for developers free from Google’s verification requirements.
The AI boom has reached not only us as users, but also our devices. For example, Android devices are silently installing large AI models without users noticing it. According to recent reports, these models cannot be uninstalled by end-users, and occupy several gigabytes of storage. The European Digital Markets Act (DMA) requires companies like Google to allow end-users to uninstall pre-loaded software on their devices. This issue is one of several that the Free Software Foundation Europe (FSFE) has formally raised in its contribution to the European Commission's public consultation on Android interoperability under the DMA.
As part of case DMA.100220 under Article 6(7) of the DMA, in which the Commission is developing binding interoperability measures for Google’s Android platform, the FSFE is calling for several improvements within the Android Open Source Project (AOSP). Among them we are asking:
- Uninstallation of AI-based features: users must be able to fully remove pre-loaded AI components, with companies prohibited from silently reinstalling or reactivating them.
- Decoupling interoperability rights from Android Developer Verification: access to Android’s interoperability features must not be contingent on registration, authorisation, or contractual relationships with Google.
“Interoperability must be decoupled from developer verification procedures. We need clear, precise, and inclusive rules to prevent circumvention by gatekeepers and to ensure that interoperability becomes a concrete reality in practice” states Lucas Lasota, FSFE Legal Programme Manager
Uninstallation of AI-based features
There is a broader pattern: gatekeepers increasingly determine which applications come pre-installed on devices, challenging the end-user capacity to fully remove those applications or their associated components. Uninstalling software should not be a temporary action that Google, and other gatekeepers, can quietly reverse. The FSFE called for clear safeguards ensuring that users can fully remove components (including AI-based features), can recover the storage space they occupied, and that companies cannot reinstall, reactivate, or update those components without the user’s prior and explicit consent.
This is not a new concern. In July 2025, the FSFE, together with other civil society organisations, filed a formal complaint to the European Commission on the lack of proper uninstallation of apps in Android devices. The current consultation represents an opportunity to reinforce and extend these protections to cover AI-based features specifically.
Decoupling interoperability from Android Developer Verification
In September 2026, Google will roll out the Android Developer Certification, forcing every Android app developer to register with Google before their software can be installed on any device. The program, criticized by Free Software developers and civil society, entails the signing of contracts and payment of account fees to Google and handing over the identity of developers. Such measures are particular problematic for Free Software developers who have deliberately chosen to operate outside Google's ecosystem, or for developers exposed to non-democratic activities in Europe and in other countries, where registering their identity with a private corporation could expose them to surveillance and retaliation risks.
The Commission's draft measures, if unchanged, would still allow Google to require developers to go through a verification process tied to the Google Play Store before accessing those features. Asking developers to register with Google or sign an agreement to access interoperability features under the DMA effectively forces them to give up the independence that makes them a real alternative. This is contrary to the text and spirit of the law.
Even where the draft measures say that access must be free of charge and technically workable, they do not prohibit Google from requiring a Google account or a developer programme agreement as a precondition. For alternative Android developers, signing such an agreement means accepting terms that can restrict what they build, how they distribute it, and what services they must pre-install. That is a real cost, even if no money changes hands.
The FSFE therefore calls on the Commission to close these gaps explicitly: no developer should need a Google account, a Play Store presence, or any agreement with Google to access Android's interoperability features.
Read the full statement here (EN).
Device Neutrality and the DMA
The Digital Markets Act is a European Union law designed to limit the power of large digital gatekeepers such as Google and Apple. One of its central goals is to make digital ecosystems more open and interoperable, so that users and developers are not entirely dependent on the conditions imposed by a handful of large tech companies. Article 6(7) of the DMA obliges gatekeepers to provide free-of-charge interoperability with the software and hardware features of their designated operating systems. For this obligation to translate into real-world openness, the measures the Commission adopts must be precise, inclusive, and enforceable.
The FSFE has been actively engaged in DMA drafting and enforcement from the outset, advocating for interoperability obligations, uninstallation rights, alternative app stores, and fair access for Free Software developers. The FSFE has also intervened directly in court proceedings concerning Apple’s DMA compliance. This contribution to the Android consultation is another step in that long-term commitment.