Can third-party transit apps receive the NFC HCE entitlement in the EEA?

Hi everyone,

I'm looking for clarity on the NFC HCE entitlement process for third-party apps in the EEA.

I've built an alternative client for Milan's public transport app (ATM Milano) on Android by reverse engineering the original app. It offers the same core functionality(users still need a valid transit subscription) just with a different UI and better UX. I'd now like to port it to iOS.

According to Apple's documentation, NFC HCE was opened to third parties in the EEA starting with iOS 17.4. However, the API requires an entitlement from Apple. I have a few questions:

  1. Is the entitlement required regardless of distribution method? Even if I distribute through a third-party marketplace like AltStore PAL rather than the App Store, do I still need Apple to grant the HCE entitlement?

  2. Are third-party/alternative clients eligible for the entitlement? My app isn't a competing transit provider, it's an alternative frontend for an existing service. Users must hold a valid subscription with the official provider. Is there anything in the entitlement criteria that would disqualify this kind of app?

  3. What's the correct process to apply?Developer Support directed me here, so I'm hoping someone from Apple engineering or someone who has gone through the process can share the steps.

Thanks!

Can third-party transit apps receive the NFC HCE entitlement in the EEA?
 
 
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