I'm developing an iOS/iPadOS remote infrastructure management app that includes native WireGuard, OpenVPN, and Tailscale/Headscale client functionality using Apple's Network Extension APIs.
The app does not operate a VPN service, provide VPN endpoints, route traffic through developer-controlled infrastructure, or have access to users' VPN traffic or credentials. Users supply their own WireGuard/OpenVPN configurations or connect to their own/existing Tailscale or Headscale networks.
Guideline 5.4 states that apps offering VPN services must use the appropriate NEVPNManager APIs and may only be offered by developers enrolled as an organisation.
Does the organisation-enrolment requirement also apply to an app such as this, where VPN functionality is a client/tool for connecting to infrastructure selected and controlled entirely by the user, rather than a VPN service provided by the app developer?
I'm currently enrolled in the Apple Developer Program as an Individual and would like to determine whether conversion to an Organisation account is required before distribution.