This doesn't count as "completely free": > Apple provides many conditions where developers do not pay the CTF: […] Developers that earn no revenue whatsoever.

This doesn't count as "completely free": > Apple provides many conditions where developers do not pay the CTF: […] Developers that earn no revenue whatsoever. This includes offering a free app without monetization of any kind (physical, digital, advertising, or otherwise). (from the link above)