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Contact App Review

Only Apple's reviewers can answer your question authoritatively. Contact Apple App Review and ask them directly.

App Store Review Guidelines

You can get a feel for what Apple will accept, see Apple's App Store Review Guidelines. In particular read Section 3.2:


  3.2 Other Business Model Issues
  
  The lists below are not exhaustive, and your submission may trigger a change or update to our policies, but here are some additional do’s and don’ts to keep in mind:
  
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  (iv) Wallet passes can be used to make or receive payments, transmit offers, or offer identification (such as movie tickets, coupons, and VIP credentials). Other uses may result in the rejection of the app and the revocation of Wallet credentials.
  
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