The same laws say the user doesn't have to use first party payment methods for IAPs anymore and you can, of course, buy an iPhone without a bank account so it's

The same laws say the user doesn't have to use first party payment methods for IAPs anymore and you can, of course, buy an iPhone without a bank account so it's very possible there will be no payment method on file and requiring one for the device to comply with local law would not fly. I think the article is right they might rely on the new location based service restriction. Even if you don't use location in your apps your phone can still know the location. Barring GNSS just connecting to a cellular network would be enough to know if it's in a region that needs to comply with this.