Two-Tier Encryption in the UK – Identical Apple Devices, Different Protection

Two identical iPhone users in the UK end up with different levels of protection because Apple removed the option to enable Advanced Data Protection (ADP) for new UK accounts after a reported secret government demand. ADP turns additional iCloud categories (backups, photos, notes, etc.) into true end-to-end encrypted data that Apple cannot decrypt. A Technical Capability Notice issued under the Investigatory Powers Act purportedly required Apple to maintain a means to access ADP-protected data for warrants; rather than build a backdoor, Apple stopped offering ADP to new UK users in February 2025. Existing users who had proactively enabled ADP before the cutoff remain protected because the setting can only be changed from the user’s trusted devices, creating a de facto two-tier encryption regime.

The dispute prompted legal and political pushback: privacy groups and the Investigatory Powers Tribunal challenged the secrecy of the notice, Apple filed complaints in 2026, and U.S. lawmakers urged the tribunal to lift gag orders that block oversight. The original global demand was later narrowed to UK users after international pressure. The core stakes are technical and democratic: forcing companies to build access undermines end-to-end encryption across services, while secret orders frustrate public scrutiny and legislative oversight.