Voucher Code IAP Violation?? 🤷‍♂️

I've looked at the App Store Review Guidelines in a lot of detail and spoke to the developer support team, but neither was able to provide a definitive answer, hence the forum post.

Scenario:
I work for a charity which offers counselling services. Pre-Covid, it was exclusively face-to-face, but now we've updated our ways and have released an app. The user registers in the app and is given all the "exercises" available. What we want to do going forward is allow local authorities to create specific "exercises" based on their needs and then give users voucher codes so they can input it into the app to get access to them tailored solutions. It's probably important to note that the local authorities are not selling the voucher codes, just providing them to users when they deem it useful for them user.

Is this business model a violation of Apple's App Store guidelines?

3.1.1 specifically states "If you want to unlock features or functionality within your app, you must use in-app purchase. Apps may not use their own mechanisms to unlock content or functionality, such as license keys, augmented reality markers, QR codes, etc."

Does this still count even though the features being unlocked are no paid features, just features based on the counselling issues the users have indicated to their local authorities and the local authorities are just providing codes to show users "exercises" to help them?



You could create a new in-app purchase that unlocks the same feature and set the price to FREE. If the user provides the code before unlocking, use this new in-app identifier ID.

Voucher Code IAP Violation?? 🤷‍♂️
 
 
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