Yes. This is what it says.
Resolution
You might not be able to see or select the None payment option for one of these reasons. If you don’t want to use a credit card, you can use another form of payment, such as a gift card.
If you have an unpaid balance or payment due
You can't select None as your payment type until you pay your balance. To see which order you need to pay for,view your purchase history on a Mac or PC. When you sign in to the store, you might see a message that there was a billing issue with your last order. Click the Billing Info button to see the order.
After you pay for the order, you can change your payment information to None.
If you’re using the iTunes Store or App Store for the first time
If you’re using the store for the first time with an existing Apple ID, you must provide a payment method. After you create the account, you can change your payment information to None.
If you’re creating a new Apple ID, you might be able to create an account without entering your credit card details.
If you changed your country or region
When you change the country or region of an existing Apple ID, you must provide a payment method and update your billing options. If you want to remove your payment method after you change the country or region, you canchange your payment information to None.
She hasn't changed countries nor regions, she's not using the either store for the first time, nor does she owe anything. She doesn't have a gift card. She's just a person without a credit card. She did have one, and now she doesn't.