Background: the Epic v. Google saga

On December 9, 2025, Google sent an email to all Google Play Developers announcing new policies and requirements related to alternative billing in the U.S. that may take effect on January 28, 2026. All of this is subject to change depending on the outcome of the January 22, 2025 settlement hearing with Judge James Donato.

These changes are the latest update in the Epic v. Google storyline, and come shortly after a few recent milestones:

• July 31, 2025 – Google officially loses their appeal and the court upholds the injunction from 2024 that forces Google to change policies due to antitrust laws. 

• October 29, 2025 – Google updates Google Play policies to allow alternative payments in the U.S. with no fees or restrictions.

• November 4, 2025 – Epic & Google file a proposed settlement to resolve their original case, which would end all outstanding litigation and apply new terms and fees to alternative payments in the U.S., in addition to other related policy updates (e.g. third-party app stores).

What do the new policies say?

The email to Google Play Developers stated, “As a part of our continued compliance with legal obligations in the U.S., we are rolling out additional changes to provide appropriate user and ecosystem protections,” with links to: an updated Payments policy, an expansion of their alternative billing programs to the U.S., and a new external content links program in the U.S. 

Two programs, one deadline

Google now offers two distinct programs for developers serving U.S. users:

1. Alternative Billing Program: Developers are required to enroll in this program to offer an alternative billing system within their app, in lieu of or alongside Google Play Billing.

2. External Content Links Program: Developers are required to enroll to be able to link users from their game to external destinations to purchase in-app digital items.

Deadline: Developers currently using alternative billing and/or in-game links to webshops must enroll and meet all requirements by January 28, 2026.

Eligibility: Both programs are available to mobile and tablet games serving users in the United States. Google explicitly notes: "App eligibility: Gaming & non-gaming mobile or tablet apps with users in the United States."

Requirements: Both programs would require developers to integrate Google's alternative billing APIs, which handle information screens, parental controls, and transaction reporting (which may allow Google to eventually charge commission fees). Beyond the technical integration, developers must provide customer support, offer refund processes, and maintain reliable access to Google Play Billing if offering it alongside alternative options.

Google outlines fees, but much unknown

Google's new policies propose a fee structure for alternative payments and external linking, but they don't state when those fees will begin to be collected. It's important to note that Google's language is "Google intends to apply a service fee," not "Google will apply." The January 22, 2026 settlement hearing could change things and this fee structure may face scrutiny. What Google has outlined here is what Google wants to do, but the legal situation is still in motion.

The fees

If those fees do take effect, the structure differs between programs:

Alternative Billing (in-app):

• 10% for auto-renewing subscriptions.

• 25% for other in-app digital purchases.

External Content Links:

• 10% for auto-renewing subscriptions.

• 20% for other in-app digital purchases.

The 20% and 25% fees align with the fee structure proposed in the Epic and Google settlement, but leave out the 9% fee tier that the settlement terms propose to apply to items that do not materially affect or advance gameplay, like cosmetic skins.

When the math stops working

If Google begins collecting the fees from these policies, the math no longer works for alternative payments and webshop linking. Paying Google 25% for alternative billing (or 20% for external links) plus your alternative payment provider’s fee (generally around 5%) puts you at or above the 30% you were trying to avoid. At that point, alternative billing and linking to a webstore lose their financial rationale. The complexity isn't worth it for negligible savings, if any. The value of these programs exists only while Google isn't collecting fees.

Even if these fees do become reality, which is still an if, direct-to-consumer on Android would be far from over. These programs only apply to alternative billing within the app and links from the app to webshops. Many games already drive significant webshop revenue through channels that don't involve in-app touchpoints at all. None of that changes.

Navigating from here

Most importantly, keep a close eye on the Epic and Google settlement hearing on January 22, 2026. We'll be watching the live stream of the hearing and plan to provide immediate updates and analysis.

That being said, the current moment (and since October 29, 2025) is unique: both iOS and Android now allow alternative payments in the U.S. with no platform fees. On iOS, this stems from the Epic v. Apple ruling. On Android, it's the result of the October 29 injunction compliance, with Google's stated fees not yet in effect.

If you're already using alternative billing on Android, Google's current policy requires you to either enroll in their program or stop by January 28, 2026.

If you're not yet using alternative billing on Android, you can launch today without enrolling and capture more revenue through January 27. Or if you plan to continue beyond January 28, you need to enroll in the alternative billing program and potentially pay the fees mentioned above (again, assuming these policies remain the same after the January 22 court hearing).

For everyone: the January 22 settlement hearing could change the picture entirely, including the enrollment requirements and fee structure. Our advice is to capture what you can now, but hold off on long-term plans or significant integration investments until we see how the court rules. Every dollar routed through alternative billing during this window avoids the 30% platform cut entirely, regardless of what happens next.

We'll publish updates on our blog as the situation develops.