This has absolutely nothing to do with that law, and even Google doesn't dare use it as an excuse for its behavior (as they did with GDPR by deliberately creating user friction that the European regulation did not require, and even partially forbids).
In reality, it's a purely political decision to curb the development of third-party ROMs, because the AOSP source code exists with all the merges and is distributed to vendors (like Samsung). However, it's not necessarily just to target GrapheneOS and LineageOS; it might also be to target the Chinese market, particularly Huawei, which uses this source code for HarmonyOS.
It absolutely has everything to do with this new law. For the first time, depending on when Google releases source code, or releases a Pixel update, the timer (4 months for security, 6 months functionality) starts. This has never existed before in Android OS' history that updates are timed (in law) according to Pixel updates/software updates or open source releases. This law also applies to Apple but they will have no problems as they are compliant anyway as they control software/hardware entirely and it's closed source.
This is the entire reason AOSP went private/closed source, and why Google is delaying security patches as per GrapheneOS. The March 2026 patches are already released by GrapheneOS as closed source blobs. They are not allowed to release them as open source by embargo (essentially NDA). Why do you think Pixel hasn't shipped security patches earmarked for March 2026? There are some critical bugs those patches fix, why not release them today, right now or next month? Because if Pixel releases just a single patch, via a Pixel update or posts it on AOSP, the 4 month timer begins for every single OEM with a phone in the EU. By making the patches under embargo, Google gets to control exactly when the timer starts to coordinate with their OEMs. So the slowest OEM gets to control the entirety of Androids security model.
Ask yourself, why doesn't GrapheneOS just release their patches publicly/open source? Why have different 'security releases' with closed source blobs?
Because if they did:
1: They lose their partner OEM access to these patches
2: Every OEM would be required to release those same patches 4 months to the day GrapheneOS releases them.
> 2: Every OEM would be required to release those same patches 4 months to the day GrapheneOS releases them.
I don't think that's true since the regulation you linked says:
> (c) security updates or corrective updates mentioned under point (a) need to be available to the user at the latest 4 months after the public release of the source code of an update of the underlying operating system or, if the source code is not publicly released, after an update of the same operating system is released by the operating system provider or on any other product of the same brand;
(emphasis mine)
GrapheneOS is not the OS provider in this context, Google is.
> at the latest 4 months after the public release of the source code of an update of the underlying operating system
So if somebody reverse engineers the patch, or releases the patch under embargo (which the OEMs would have the source code) that would count as a 'public release'. So GrapheneOS can ship closed source patches as you are right, they are not the provider. If GrapheneOS released the source code they are getting from their OEM then it would count as a 'public release of the source code'.
A patch in itself can be considered an 'update of the underlying operating system' and therefore the moment it becomes public it needs to be patched by all OEMs within 4 months.
GrapheneOS have themselves said that if somebody did reverse engineer the closed source blobs and posted them publicly they could then ship the patches openly at that point but not until.
It must be stated a lot of the wording of this clause and interperetation of what is/is not considered 'publicly releasing source code' is up for debate/courts to settle.
> Because if Pixel releases just a single patch, via a Pixel update or posts it on AOSP, the 4 month timer begins for every single OEM with a phone in the EU.
And that's exactly what the law was about, this timer is a good thing. Now they should close the "artificial delay" loophole.
In reality, it's a purely political decision to curb the development of third-party ROMs, because the AOSP source code exists with all the merges and is distributed to vendors (like Samsung). However, it's not necessarily just to target GrapheneOS and LineageOS; it might also be to target the Chinese market, particularly Huawei, which uses this source code for HarmonyOS.