Given that Apple already maintains a comprehensive entitlement system[0] they charge EU developers[1] to use, I don't see how that's an issue. Apple's work amounts to swapping out a .plist file, they could be compliant in 10 minutes with an OTA update. If they wanted.

[0] https://developer.apple.com/documentation/bundleresources/en...

[1] https://developer.apple.com/support/compare-memberships/