Maybe. I’m actually curious how they are going to gate it. Because I’m originally from the US, I have access to US things still (like Apple Cash). I’ve migrated my account years ago, and my phone’s region is set to my EU one.
There's some investigation as to how Apple uses countryd to determine what jurisdiction you're in.
>[countryd] combines multiple data such as current GPS location, country code from the Wi-Fi router, and information obtained from the SIM card to determine the country the user is in.
I read somewhere that Apple ID region will be part of it. Given they don't let you transfer your purchases from one Apple ID region to another, it'll be a nightmare for people living in the EU but using a US Apple ID account.
I feel like that’s a bit disingenuous to what actually happens when you change regions. As they explained to me before I switched:
1. All my content would stay in the old region. If I ever go back, I will still have all that content.
2. In my new region, content will be matched. If there is matching content, I will have a license for it. Otherwise, I will lose access to the content until I change my region back.
I accepted and that’s what happened. Some of my old playlists are full of content I can’t play here (for the better playlists, I just got the EU version of the song and deleted the US version). I still see most of my apps and movies/shows in library. Some apps that are US only stopped updating until they eventually stopped working.
Interesting. It's been a decade since I looked into this but unless I was just unlucky and no content matched, your second point is a big improvement since then.
I did this in 2018, and I had to do it over the phone because my account was bugged (stuck in an infinite loop, and even on the phone I was eventually handed off to someone relatively high-up in the corporate ladder, after six hours of being passed around to various departments) and I remember her mentioning that it was relatively new.
I am also not a lawyer, but asking if someone is an EU citizen is probably not acceptable in and of itself.
The DMA Chapter 1 Article 1 section 2 makes it clear that the requirement applies to services offered to users “established or located” in the EU.
You can be located in the EU without a residence permit or citizenship perfectly legally (and it’s not even clear whether being LEGALLY located or established in the EU is a requirement).