Does a "penalty/commitment" charge for skipping daily tasks require In-App Purchase?

Hi everyone,

I'm building an iOS app (a language-learning app) with an unusual monetization model, and I'd like to confirm how StoreKit / IAP guidelines apply before I implement payments.

The model

  • Users set a "commitment": they pledge to complete one short quiz every day.
  • If a user skips (no activity for two consecutive days), a pre-agreed penalty amount (e.g. 500 JPY) is automatically charged to the card they registered at sign-up.
  • The app itself, and all learning content, is free. Users are NOT paying to unlock features, content, levels, or any digital goods.
  • The charge is purely a commitment/accountability penalty, similar in spirit to services like Beeminder or stickK. The money is a consequence of NOT acting, not a purchase of anything.

My question

Would this penalty charge be considered a purchase of "digital content or services" that must go through In-App Purchase (per Guideline 3.1.1)?

Or, because the user is not buying any digital goods/features and the charge is a real-world commitment penalty, would it be acceptable to process it through an external payment provider (e.g. Stripe)?

I've read Guideline 3.1.1 and 3.1.3, but I'm unsure which category a "penalty for inaction" falls into, since it doesn't unlock anything in the app.

Any guidance, or pointers to relevant guideline sections or precedents, would be greatly appreciated. Thank you!

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Does a "penalty/commitment" charge for skipping daily tasks require In-App Purchase?
 
 
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