BRUSSELS, Oct 22 (Reuters) - Apple ( AAPL ) was hit with

a complaint to EU antitrust regulators by two civil rights

groups on Wednesday over the terms and conditions of its App

Store and devices for allegedly breaching landmark rules aimed

at reining in Big Tech.

The joint complaint by Article 19 and Germany's Society for

Civil Rights to the European Commission could pose yet another

headache for Apple ( AAPL ), which was fined 500 million euros ($583

million) in April for violating the Digital Markets Act.

Apple ( AAPL ), which has previously said its rules ensure

marketplaces meet specific minimum requirements to protect users

and developers, dismissed the claims as false and put the blame

on the Commission.

"The EC is mandating how we run our store and forcing

business terms that are confusing for developers and bad for

users," Apple ( AAPL ) said in an email.

"Months ago, we notified the EC of our plans to roll

out additional changes to the letter of credit requirements to

provide more flexibility for developers but the Commission asked

us not to."

The EU executive, which acts as the bloc's competition

enforcer, said it was aware of the submission.

"Third party contributions are very important for the

effective enforcement of the DMA," a Commission spokesperson

said.

"We are already looking into (some of) those issues, as we are

currently seeking feedback from market participants in relation

to Apple ( AAPL ) business terms and we are regularly supervising

gatekeepers' compliance."

The DMA sets out a list of dos and don'ts for Big Tech firms

aimed at allowing smaller rivals entry into markets dominated by

the largest companies and giving users more choice.

The complaint targets Apple's ( AAPL ) business terms and conditions

for its App Store, iOS and iPadOS operating systems, saying that

these prevent and impede interoperability for small businesses

with Apple ( AAPL ) devices.

It also takes aim at restrictions on the installation and

use of third-party software apps and app stores which it said

harm business users and end users in breach of the DMA.

The civil rights groups singled out a stand-by letter of

credit (SBLC) of 1 million euros required from developers who

want to develop apps for distribution in Apple's ( AAPL ) App Store or

who want to install a third-party app store as a native app in

Apple's ( AAPL ) iOS and iPadOS.

"A 1,000,000 euro SBLC can impose a recurring annual cost

and collateral requirements that many SMEs cannot meet," said

the 16-page complaint seen by Reuters.

The groups urged the Commission to fine Apple ( AAPL ). DMA penalties

can be as much as 10% of a company's global annual revenue.

($1 = 0.8575 euros)