Is there a public API or entitlement for a user-controlled Apple Pencil annotation overlay across iPadOS apps?

Hello, I am exploring an iPadOS product idea for Apple Pencil users and would like to understand the current public API boundary. The user need is a temporary, user-controlled Apple Pencil annotation layer while the user is working in another app or workspace. For example, a student may be reading in Books, Safari, a PDF app, or another educational app and want to write quick Pencil notes directly over the visible material without taking a screenshot or exporting the content first. I understand that PencilKit works inside an app's own UI, and I also understand that iPadOS sandboxing prevents third-party apps from inspecting or modifying other apps. I am not trying to bypass that model. What I am trying to determine is: Is there any current public API, extension point, or entitlement that allows a user-initiated Apple Pencil overlay session across the current iPadOS workspace? If not, is Feedback Assistant the right place to request a new PencilKit / iPadOS entitlement for this use case? Are there existing Apple-recommended patterns for this workflow beyond Quick Note, Screenshot Markup, Split View, Stage Manager, or importing content into the developer's own app? The privacy model I have in mind would be strict: The overlay is user initiated only. A visible system indicator is shown while active. The developer app receives Pencil stroke data only by default. The app cannot inspect the underlying app's view hierarchy, documents, text, or private data. Screen pixels are not captured unless the user grants separate explicit permission. The user can close or clear the overlay at any time. The closest mental model is a system-mediated Pencil annotation layer, not a background screen recorder or a way to control another app. If this is not possible today with public APIs, I would appreciate confirmation so I can file a clear enhancement request through Feedback Assistant. I also filed this as Feedback Assistant report FB23067750. Thank you.

Is there a public API or entitlement for a user-controlled Apple Pencil annotation overlay across iPadOS apps?
 
 
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