Please consider adding an additional rule aso to get certified is device can not require the device manufacturers own apps to be installed or configured, as such apps may be removed from Apple and Google app stores in the future which makes the device useless.
Nuki is an example here which got a Matter device certified, yet it requires that you first install the Nuki app to generate the QR code needed for Matter commisioning. That means that Nuki Matter device can never be reinstalled if the Nuki app is removed, which we known can happen if a company closes or is aquired.
Nuki or whoever makes their app in the future could also start requiring cloud login to use their app. Having such a clause in the rules would prevent such rugpulls from happining. Because if the commisioning of a device is not a key functionality that need to follow compliance rules for certifications then that really needs to be made very clear.