App Store Guidelines: auto-renewable subscription offer code as non-consumable alternative?

Hi,

My app currently offers a non-consumable in-app purchase to unlock all its features, and I would like to provide this full access for free to an organization with a few thousand Macs.

Since Apple limits non-consumable in-app purchase promo codes to 1000 per app, this isn't sufficient for the organization's size. So I'm considering an alternative approach using an auto-renewable annual subscription with offer codes:

  1. Create a few thousand offer codes for an annual subscription.
  2. Users within the organization would redeem these codes.
  3. Instruct users to immediately unsubscribe after redeeming the code.
  4. The app would then check the in-app purchase receipt. If the receipt contains a transaction redeemed with an offer code, the app would treat this as a permanent unlock of all features.

My concern is that repurposing an auto-renewable subscription in this manner—effectively turning it into a lifetime unlock triggered by redeeming an offer code and immediately cancelling—might violate App Store guidelines.

Is using an annual subscription and offer codes this way likely to be compliant with App Store guidelines?

Thank you for your guidance!

App Store Guidelines: auto-renewable subscription offer code as non-consumable alternative?
 
 
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