The German law to force Apple to open it’s “NFC chip” is a confusing one. Why does an EU country with one of the lowest cashless usage rates single out one company’s NFC product in a last minute rider to an anti-money laundering bill? That’s not banking policy, it is politics. Details are few but let’s take a look at what it could mean because when it comes to NFC technology, details are everything.
The so called Apple ‘NFC chip’ is not a chip at all but a hardware/software sandwich. The Apple Pay ecosystem as described in iOS Security 12.3 is composed of: Secure Element, NFC Controller, Wallet, Secure Enclave and Apple Pay Servers. On one end is the NFC chip controller front end that handles NFC A-B-F communication but does not process transactions, on the other end there is the Secure Enclave that oversees things by authorizing transactions. The fun stuff happens in the Secure Element middle where the EMV/FeliCa/MIFARE/PBOC transaction technologies perform their magic with Java Card applets.
The A/S Series Secure Enclave and Secure Element are the black box areas of Apple Pay. The iOS Security 12.3 documentation suggests the Secure Element is a separate chip, but Apple’s custom implementation of the FeliCa Secure Element, and the apparent ability of Apple to update Secure Element applets to support new services like MIFARE in iOS 12 suggests something else, but it is anybody’s guess. Apple would like to keep it that way.
So what does ‘open NFC’ really mean?
It’s helpful to look at the issue from the 3 NFC modes: Card Emulation, Read/Write, Peer to Peer.
Peer to Peer
Apple has never used NFC Peer to Peer and I don’t think this is a consideration in the ‘open NFC’ debate.
This was a limitation up until iOS 12, but everything changed when iOS 13 Core NFC gained Read/Write support for NDEF, FeliCa, MIFARE, ISO 7816 and ISO 15693. Developers can do all the NFC Read/Write operations they want to in their apps, I don’t think this is a consideration in the ‘open NFC’ debate.
Apple limits NFC Card Emulation to Apple Pay Wallet with NDA PASSKit NFC Certificates. This is what the ‘open NFC’ debate is all about. I imagine that German banks and other players want to bypass the PASSKit NFC Certificate controlled Apple Pay ecosystem. Instead, they want open access to the parts they want, like Secure Element, NFC Controller, Secure Enclave, and ignore the parts they don’t want like Wallet and Apple Pay Servers. They want the right to pick and choose.
The success of Apple Pay has been founded on the ease of use and high level of integration from a massive investment in the A/S Series Secure Enclave and other in-house implementations such as global FeliCa, etc. Outside players forcing Apple to open up the Apple Pay ecosystem represent not only a security risk to Apple but also a reduced return on investment. One commentator on MacRumors said it’s like Apple took the time and expense to build a first class restaurant and outsiders are demanding the right to use Apple’s kitchen to cook their own food to serve their own customers in Apple’s restaurant. It’s a fair analogy.
The NDA PASSKit NFC Certificate gate entrance rubs bank players the wrong way as they are used to dictating terms, not accepting them. The Swiss TWINT banking and payment app for example is a QR Code based Wallet replacement that wanted the ability to switch NFC off, and got it.
My own WWDC19 Apple Pay Wish List did include a wish for easier NFC Card Emulation, but nothing appeared. It’s certainly in Apple’s best interest to make it as easy as possible for 3rd party developers to add reward cards, passes, ID cards, transit cards, etc. to Wallet. However given that the EU is hardly what I call a level playing field, the fact that bank players and politics go hand in hand in every nation, and the fact we don’t know the technical details of what the German law is asking Apple to do, all we can do is guess. In general, I think Europe will be a long rough ride for Apple Pay. At least until EU bank players get deals, and branding, they are happy with.