Apple seems to be bouncing ideas off the EU with respect to compliance here. Realistically I guess they have one “grace period,” however long that is, before they start violating anybody’s rights. So, they could take that time to negotiate with the EU and come up with a way to prove your EU citizenship outside the EU.

I don’t think the EU cares to protect us Americans just because we imported a phone from the EU. So, I bet it’ll be citizenship based somehow.

Residency not citizenship. A country's laws apply to anyone in the country not just its citizens. Technically if you are American visiting EU the DSA consumer protection applies to you the moment you land.

The law applies to Apple’s presence in the EU. The EU could order Apple’s EU branch to allow anyone to install an App Store. In the sense that sovereign states can write their laws however they want.

Looking into it, they use the phrase “end user” a lot, but don’t seem to specify resident, citizen, or anything, at least as far as I see. It is a complicated law so I probably missed it.

People here seem really confident about who’s covered, but nobody is providing links, so I think everybody is just going off vibes.

The DMA allows for fines of up to 10% of total worldwide turnover. I'm not sure this is a fight Apple should be picking.