iOS 27.2 ATT changes: Is migrating to the new API required to access IDFA in five EU countries?

Hello Apple engineers and fellow developers,

We plan to distribute our iOS / iPadOS games in Germany, France, Italy, Poland, Romania, and other EU countries. We would like to clarify whether the ATT changes introduced in iOS / iPadOS 27.2 require developers to adopt the new authorization API.

We currently request tracking authorization using:

ATTrackingManager.requestTrackingAuthorization(completionHandler:)

We access IDFA only after the user grants ATT authorization.

We reviewed the following official documentation:

1. User Privacy and Data Use — ATT in the European Union
   This page states that, beginning with iOS / iPadOS 27.2, only the alternative ATT system prompt is available for apps distributed in the five countries listed above due to legal requirements.

2. requestTrackingAuthorization(completionHandler:) — API Documentation
   The documentation states that the system presents a full-page sheet in these five countries when this existing API is called.

Based on these documents, our understanding is that the existing API automatically presents the appropriate alternative ATT prompt in these countries. Therefore, developers do not need to migrate to the new API with the preferExpandedInterface and additionalInformationAction parameters solely to request authorization and access IDFA.

Could you please clarify the following?

• Is this understanding correct? Can games distributed in these five countries continue using the existing API and access IDFA after the user grants authorization?
• Is adopting the new API also optional in other EU countries?
• If migration is mandatory, could you point us to the official requirement, applicable OS versions, and effective date?

Our question concerns Apple’s ATT API integration and migration requirements, so we can plan the necessary SDK updates.

Thank you for your help!