More details in the developer portal: https://developer.apple.com/support/apps-in-the-eu/

It seams that for "reader apps" (like Netflix / Spotify), things got slightly better (https://developer.apple.com/support/reader-apps/#:~:text=16....):

> Beginning October 1, 2026, reader apps distributed in the EU may promote out-of-app offers for digital goods and services without an actionable link [...]

So you can now at least promote your offers, which was forbidden previously.

A reader app is, in Apples words: "With reader apps, people can sign in to their account created outside the app, letting them view and enjoy previously purchased media content or content subscriptions on their Apple device."