There is also this requirement though:

> In order to establish adequate financial means to guarantee support for developers and customers, marketplace developers must provide Apple a stand-by letter of credit from an A-rated (or equivalent by S&P, Fitch, or Moody’s) financial Institution of €1,000,000 prior to receiving the entitlement. It will need to be auto-renewed on a yearly basis.

Source: https://developer.apple.com/support/alternative-app-marketpl...

It doesn't seem like the fee waiver removes this requirement.

And it seems like the cost for a standby letter of credit is roughly 1-10% of its value per year? So effectively it costs €10,000 to €100,000 per year just to have an alternate marketplace, separate from the core technology fee....