Context: ACT | The App Association has for decades been claiming to represent thousands of small software developers, at some point calling them all app developers, only to include Internet of Things (IoT) overnight at some point. But it has from the beginning been funded by large tech companies and even by its own admission isn’t taking any membership fees from the entities it claims to represent. A major news agency exposed the scheme (September 19, 2022 Bloomberg article), eliciting an admission by ACT that more than half of its funding came from Apple and quoting former ACT staffers who thought this was a gross understatement and that Apple was in fact controlling the organization. Anyone even half-knowledgeable in tech policy can easily see that ACT | The App(le) Association solely advances Apple’s interests, advocating causes that are either irrelevant to app makers such as standard-essential patents (SEPs) or taking positions that benefit Apple and harm app makers (such as in the App Store governance context). Acting as a puppet of one stakeholder or group of stakeholders while falsely claiming to be on the side of an entirely different (or even opposing) category of stakeholders is called “astroturfing”.
What’s new: A couple of weeks ago, ACT | The App(le) Association announced that it “has officially joined the European Telecommunications Standards Institute (ETSI)” and intended to “work[] closely with other ETSI members (June 9, 2025 press release by ACT). But ACT is absolutely positively not an ETSI member! As we have found out from several independent ETSI members, ACT has merely applied for membership and there is considerable resistance to this astroturfing scheme, requiring a vote at an ETSI General Assembly in November where ACT needs a supermajority to be admitted.
Direct impact: ACT’s untruthfulness may be yet another reason for ETSI members to oppose this membership application that is just designed to give Apple additional voting rights and to let ACT claim that the U.S. non-profit corporation (as opposed to an assoication that votes its leadership) is recognized by ETSI as a representative of small and medium-sized enterprises (SMEs) (which it is not because it is financially entirely dependent on Apple and, secondarily, a few other large companies), and potentially to make public statements as an “ETSI member.”
Wider ramifications: ACT’s brazen astroturfing has not led various European Commission (EC) officials to refuse to engage with ACT or invite it to events. That does not lend legitimacy to ACT, but just one of the ways in which the EU fails its companies and citizens.
Under the headline “Bringing the SME Voice to Digital Standards: ACT | The App Association Joins ETSI”, ACT announced “ha[ving] officially joined” ETSI. But they would have to become an actual member to “officially join[]” and to be able to talk about what they will do “with other ETSI members.” Nowhere does ACT’s announcement (at least at the time that this article was published; maybe it will trigger a correction) state the truth, which is that they have nothing more in place than a pending application.
Here’s what Perplexity.ai says about this:
If someone says they have “officially joined” a membership-based organization, this almost always means they are now a member—not just that they have applied.
Explanation:
- The phrase “officially joined” implies that any necessary steps (such as applying, being approved, and possibly paying dues) have been completed.
- It suggests their membership is recognized and formalized by the organization.
- If someone had only applied, they would typically say “I have applied” or “I am applying,” not “I have officially joined.”
In summary:
“Officially joined” = They are now a recognized member of the organization.
For the avoidance of doubt, the following information was not provided to us by ETSI, but by a member and corroborated by other members. On Monday, ip fray visited ETSI (which is headquartered in the same region, the Côte d’Azur), but ACT was not a topic of discussion. At the time we were not even aware of ACT’s pending membership application. When we inquired subsequently, ETSI did not tell us more than that ACT had applied for membership.
The path to ETSI membership is normally smooth. They already have 900 members, and it is highly unusual if not entirely unprecedented for there to be stiff resistance to an application. But ACT is an outrageous case and would set a terrible precedent as deep-pocketed companies could do an end-run around the per-member cap of the number of votes and astroturfers like ACT could use ETSI to portray themselves as something they actually aren’t.
Normally, memberships go through based on an online vote, of which there is one per quarter, by there being no objection. Here’s a screenshot of the voting form that was taken a few days ago (we have redacted, with a black bar, only the area where the name of the member who provided it was displayed):
It adds to the overall absurdity that ACT describes itself as a “Full Manufacturer” when it never made a product. Manufacturing fake memberships would not count. As a recipient of government funds under the COVID-era Paycheck Protection Program (PPP) in the United States, ACT applied as a non-profit corporation. Non-profits can be ETSI members, but the other ETSI members do not have to tolerate an entity that pretends to be what it is not. No one in his right mind will believe that a company funded by Apple and some other large companies and (as it told EU politicians in a letter) does not take money from small companies really has SME interests in mind. The agenda is to serve Apple and the others who pay the piper and pick the tune.
In the SEP context, it is ridiculous because app makers simply use implementations of standards that are available at the operating system and hardware levels. In the App Store governance context, a neofeudal and tyrannic system, it is the equivalent of a Russian-funded astroturfing group claiming to speak for the average Ukrainian citizen.
The next two screenshots show that the poll is still open until just before midnight from Saturday (June 21, 2025) to Sunday:
There are some reputable names among those applying simultaneously with ACT: Datang is a major mobile innovator from China; the Eclipse Foundation is a leading open-source organization; Europol is the EU-level police body; and Zoom needs no introduction. No doubt that they will sail through the online vote. ACT will not: we have received assurances from multiple sources that there will be resistance.
At this point, it takes only one member to vote against ACT’s application, and then, according to a May 28, 2025 letter by ETSI Director-General Jan Ellsberger to all full and associate members, “[t]he application(s) having received objections will be submitted at the next General Assembly meeting.” That one will take place in November.
ACT is not merely jumping the gun by declaring itself a member when the earliest point in time where it can become one is still months away. ACT is being presumptuous, given that the outcome of the vote could easily be a rejection of its sham application.
ETSI does not need astroturfers, and it already has SME representatives among its 900 members. There always is the possibility that an SME association takes positions that a majority of SMEs would not support. That’s association politics. But in order for an organization to make a credible claim that it is an SME body, SMEs must be the ones paying for everything and making all the decisions. Nowhere does ACT have a full membership directory. To the extent it lists a few dozen companies, they tend to be mostly service providers as opposed to companies selling their own products.
At ACT events, there are typically just ACT staffers, ACT consultants and a few guests such as the European Parliament’s failed rapporteur on the SEP Regulation (June 19, 2025 ip fray article), Marion Walsmann MEP, herself a former astroturfer: as a puppet of the East German dictatorship, she pretended to be a center-right politician, but her party was a fake organization that was actually just controlled by the governing Socialist Unity Party and virtually always voted in favor of the dictatorship’s proposals.
On social media it’s a similar picture: ACT’s post, such as on X, typically draw support only from ACT’s staffers, ACT’s consultants, Apple employees, and service providers.
If the EU institutions wanted, they could easily promulgate a rule that an organization claiming to represent a category of companies must be fully funded by that category of companies and all the decisions, including appointments and budgets, must be made by actual members. ETSI is not an EU institution. The EC just played a major role in its creation. In ETSI’s case, it is now up to the members to make the right choice and say no to astroturfing.
ETSI can survive a lot of things, including an ACT membership. But ACT’s involvement would cause unnecessary distraction and be unhelpful in many ways. In the end, ETSI may have to deal with more and more members of that kind, which would adversely affect its ability to do its important work.