Two-Tier Encryption in the UK: Identical iPhones, Different iCloud Protection
In the UK, two owners of identical iPhones can now have different levels of iCloud protection: those who enabled Apple's Advanced Data Protection before February 2025 keep it, while everyone else cannot switch it on.
Two people in the UK can own identical iPhones, use iCloud and pay Apple for the same services, yet hold different levels of protection for their data. One enabled Advanced Data Protection (ADP) before Apple withdrew the feature for new UK users in February 2025 and still has it. The other cannot switch it on at all.
How the two tiers appeared
On 7 February 2025, The Washington Post reported that the UK government had ordered Apple to give access to data protected by its strongest iCloud encryption, using a Technical Capability Notice under the Investigatory Powers Act 2016 — a legal instruction requiring a provider to keep the technical ability to comply with future warrants. It was reported to have been issued in secret in January 2025 and to cover users worldwide, not just the UK.
On 21 February 2025, Apple said ADP would no longer be available to new UK users, stating that it had "never built a backdoor or master key to any of our products or services".
What ADP changes
All iCloud data is encrypted, but not all of it end-to-end. Fourteen categories are end-to-end encrypted by default. ADP raises the total to 23, adding iCloud Backup, Photos, Notes and iCloud Drive. Apple holds no keys to those categories and cannot decrypt them on request.
Why Apple could not switch it off
Apple stopped new UK users from enabling ADP but did not disable it for existing ones. Its security documentation says the setting can only be changed from the user's trusted devices; Apple's servers cannot modify or roll it back. Apple says existing UK users will get time to disable ADP themselves, but no deadline has been published.
Where the dispute stands
The original demand covered users worldwide; late in 2025 it was replaced by a narrower notice affecting only UK citizens, after the Trump administration applied pressure. In July 2026, Apple lodged a fresh complaint at the Investigatory Powers Tribunal. On 11 September 2026, US Senator Ron Wyden and Congressman Warren Davidson urged the tribunal to open its proceedings, and on 17 September The Daily Telegraph reported that Apple had asked it to lift secrecy restrictions so that "facts [can] be deployed in the open", as its lawyer Daniel Beard KC put it.
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