That’s not how I interpret that. I think they’re just saying that if your app does offer digital goods, you have to use IAP. Not that any app in this category has to include IAP to be accepted.

Apple is protecting its bottom line here. In other words if Nintendo was to release a classic arcade, they don’t just get to circumvent IAP rules in non-DMA countries because of this change. But I don’t see any wording that says apps cannot forgo offering any IAPs and just allow you to add content via Files like all other apps do.

If they intended your definition, they wouldn’t leave it vague. There would be a specific provision that says “Apps cannot access files or software from the system, or offer an in-app browser or other online resource to add files to the app.”

Moreover, this change is specifically targeted at Riley Testut and AltStore, which was founded so he could distribute his emulator, Delta. Your interpretation would fully prevent that app from being offered, so I really don’t think that is what Apple was intending.

Lack of JIT is crippling though, hopefully that will change soon.