Billing

their rule has always been one has to have a valid means of payment to access their app and itunes store

Change, add, or remove Apple ID payment methods - Apple Support

This is a user helping other users with tech questions

forum, you are not addressing apple here  just  fellow users

 you can suggest they alter that stance by

you can try contacting apple Get Support (apple.com)

and or give them feedback Product Feedback - Apple

You need a valid payment method to download any app, be it free or paid. Free apps often offer in-app purchases that you need an active method to pay for.

You can simply remove the payment method and see if that solves the problem. Hope this helps!