We are developing a non-custodial cryptocurrency wallet app with the following characteristics:
Architecture:
- Users hold their own private keys at all times (we never custody any assets).
- The app includes identity credential verification: KYC-verified identity data (Verifiable Credentials / DID-based) is exchanged between the payer's iPhone and a counterparty device for identity verification purposes.
NFCTagReaderSessionis used only to exchange identity credential data via our proprietary, non-payment ISO 7816 AID with the counterparty device.- Cryptocurrency transactions are submitted entirely over the internet (blockchain RPC), completely independent of the NFC session.
NFC is NOT used to:
- Transmit cryptocurrency or payment instructions.
- Interact with any EMV payment AID or Secure Element.
- Replace or emulate Apple Pay or any payment card.
Jurisdiction & licensing context: The app is being developed by a Japanese company for initial launch in Japan. While this question is posted from an individual Developer account for inquiry purposes, the app itself will be submitted under an appropriate Organization Developer account of the operating company, in compliance with Guideline 3.1.5(a)(ii). We are working with Japanese legal counsel to obtain any applicable Japanese financial-services license (e.g., 電子決済手段・暗号資産サービス仲介業 / Electronic Payment Instruments and Crypto-Asset Service Intermediary Business under the 2023-amended 資金決済法 / Payment Services Act) prior to App Store submission, and a written legal opinion will accompany the submission. We are not seeking to qualify as a 暗号資産交換業 (crypto-asset exchange) or 資金移動業 (funds transfer service operator), as our non-custodial design is intended to fall outside those categories under Japanese law.
Question:
Under Guideline 3.1.5, does a non-custodial wallet that uses NFCTagReaderSession solely for identity credential data exchange (not for transmitting cryptocurrency or payment instructions over NFC) fall under the "Wallets" sub-category — requiring an Organization Developer account only — or does NFC involvement for identity verification shift it toward a sub-category requiring additional licensing, entitlements, or financial institution credentials?