Can I generate apple wallet passes for other bussinesses?

My idea is to help small businesses (without IT infrastucture) generate apple wallet passes for their customers (to identify them later). All the data would be stored in my database and will be accessible by businesses. So Customer would show apple wallet pass which business would be able to scan and fetch customer info from my database. And businesses would be able to create/modify their passes through my app.

Can I generate apple wallet passes using my pass type id?

In https://developer.apple.com/forums/thread/48719, one of the comments mentioned:

You agree not to ... use Your Pass Type ID to sign a third party's pass.

I haven't seen this rule anywhere on apple's website, so not sure if it is still active.

and distribution needs to be under Your own trademark or brand.

Does that mean I can't generate passes for other businesses? Although, I am providing service related to wallet passes and pass generation is not part of the main service itself.

If so, is there any legal workaround for my use case? E.g. maybe putting my company logo as main logo etc.

Thanks!

P.S. creating paid apple developer account to obtain business' own pass type id and certificate is not a viable solution

Can I generate apple wallet passes for other bussinesses?
 
 
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