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Apple plans to charge fees for sideloading
(9to5mac.com)
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this post was submitted on 24 Jan 2024
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Your description matches my understanding of the process (as someone who left iOS development a few years ago).
I don’t think that the DMA is technical enough to differentiate in this precise manner. Keep in mind that it was written by lawmakers and politicians who mostly don’t know how to even use a smartphone. They'd think that a certificate is a piece of paper with fancy signatures on it.