White-label healthcare apps for multiple independent clinics per-client apps vs aggregated model (4.2.6, 4.3(a), 5.1.1(ix))

I'm an iOS developer in India, not yet enrolled, and I want to confirm my distribution architecture before I incorporate and pick an account type. What I'm building: patient-facing appointment and clinic-management apps for independent single-doctor clinics. One shared codebase; branding, clinic details, and backend configuration differ per clinic. The clinics will not enrol in their own Apple Developer Program accounts. I would register a company and enrol as an Organization, that company provides the software platform, while the medical services are provided by the individual clinics.

  1. Under 4.2.6 and 4.3(a), is a separately branded app per clinic viable from a single Organization account? My reading is no, and that the aggregated or "picker" model, one app where patients select their clinic, is the intended path. Is that correct?

  2. Under 5.1.1(ix), for that aggregated app, is my company an acceptable seller given that the medical services themselves are delivered by the clinics? Or does Apple expect each clinic to be the seller?

  3. If separately branded per-clinic apps are only possible when each clinic enrols in its own account, can I be added to their teams and submit on their behalf, or must the clinic itself submit?

  4. Are there additional review requirements for apps tied to medical practices, clinic licensure documentation, proof of authorisation to publish on their behalf, or a regulated medical device declaration, where the app only handles appointments, records, and clinic administration rather than diagnosis or measurement?

Developer Support case 20000147392668 (they directed me here for the guideline questions).

White-label healthcare apps for multiple independent clinics per-client apps vs aggregated model (4.2.6, 4.3(a), 5.1.1(ix))
 
 
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