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My idea is to help small businesses without an IT infrastructure to generate Apple Wallet passes for their customers to identify them later. All the data would be stored in my database and will be accessible by the businesses. A customer would show an Apple Wallet pass which the business would be able to scan and fetch customer info from my database. Businesses would be able to create/modify/distribute their passes through my app.

In https://developer.apple.com/forums/thread/48719, one of the comments mentioned:

You agree not to ... use Your Pass Type ID to sign a third party's pass.

I haven't seen this rule anywhere on Apple's website, so I'm not sure if it is still active.

Distribution needs to be under your own trademark or brand.

Does that mean I can't generate passes for other businesses although I am providing service related to wallet passes and pass generation is not part of the main service itself?

  • I’m wondering if there is any legal workaround for my use case ( putting my company logo as main logo)
  • Creating paid Apple Developer account to obtain business' own pass type id and certificate is not a viable solution.

Can I generate Apple Wallet passes using my pass type id?

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  • Good research. I wish you luck and surely if I’m wrong, someone will edit my answer or provide better ideas and commentary here.
    – bmike
    Commented Nov 9, 2023 at 2:37

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I believe your idea is not viable due to Apple’s license terms.

Whether you resell the capabilities to sign wallet passes to your customers or give it away free, you’re going to be in violation of attachment 5 paragraph 1 of the developer license agreement. You would need a separate agreement with Apple unless you could convince them you are licensed by the owner of the pass content and they give you the green light. Your lawyer can help best with the legal aspects of my opinion and your ideas.

I would price your business model so you can cover the costs for each business to have their own developer license and you would be their vendor to help them enroll, manage and maintain their developer program and then perform work to assist them in signing their own passes. The beauty of this approach is the businesses don’t need any IT infrastructure with you as their tech vendor. Apple allows your Apple ID to be associated with several other accounts as a developer when they onboard and grant permissions to you in order to act on their behalf.

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