This requirement to be eligible for Web Distribution in the EU seems whack. Essentially, you have to have had a somewhat successful app distributed on the App Store (or an alternative marketplace?) and have had an Apple Developer account for two years before being eligible for Web Distribution.
This sounds like Apple doesn't want to allow companies to launch their app via Web Distribution but rather transition from a store to Web Distribution.
From https://developer.apple.com/support/web-distribution-eu/.
