I believe the actual requirement is apps have to work without location access if it isn't essential to the basic functioning of the app. A GPS navigation app obviously needs location access to do its job, something like Twitter, not so much.

Bad example.

Yes, the core gameplay doesn't work, but the app still allows you to log in, manage your account mess with your existing Pokémon and items, move those Pokémon into Pokémon Let's Go's Go Park on the Nintendo Switch.

If you try to play the core game with location permission permanently disabled, the game will alert the user that the game needs the location permission enabled but it will NOT lock the user out of those other functions.

Manage your newly created account.

I'm not familiar with the AppStore guidelines myself, but for the most part pokemon go only needs your location while using the app. perhaps that makes a difference?

there are some pokemon go features (adventure sync) gated behind always-on location access, but it isnt required.