I don't think that Apple can request this as it would be against European law. Nobody can control if somebody who is German has a second living destination in Ireland and as traveling and economics are free in the EU you can get a bank account in other EU countries.
Same with bunq. They could issue you an Italian / Spanish Maestro card or MasterCard. Still, doesn't work any more, does it?
EU law states that you get (at least one basic) account / credit card in any single EU member state. But EU law doesn't state (and wouldn't be able to) that you have a right to add that card to a digital wallet. That lies with the tech companies and so Apple can decide if you can add your bunq/boon card to Apple Pay or not. Those are two different things I'm afraid.
There are still top secret contracts between the banks and Apple that we know absolutely nothing about. I'm sure part of it is restricting EU banks with multiple branches to only provide Apple Pay to users in that specific country. N26 has showed in the past that it will block your account if they detect you getting around those restrictions. Bunq publicly advertised the work-around and got into trouble. Boon does the same but doesn't advertise it. Maybe that is because it's a virtual operator only or because their contract with Apple was agreed upon long before these use-cases with foreign users became apparent.
A while back rumours spread that Apple actively allowed boon to issue foreign users access to Apple Pay (so to satisfy the "nerds"). Who knows if that is true. Another point is a bargaining chip: Apple sometimes gives banks exclusive access to Apple Pay for a certain period of time. Let's take the bunq example: If they had allowed bunq to carry on giving Dutch and German users access, Apple would not have been able to / will not be able to offer ING (NL) or Sparkasse (DE) (...) any convincing exclusivity agreement for a launch. That's why Apple is strong on this topic to keep control over their platform and not loose control and let the banks dictate the rules.