Excellent take. Had Apple made a dummy proof "Pass" portal for clubs, venues, etc to use to visually design and manage passes (and maybe even distribute?) when they launched this, I think it would have exploded, and the ecosystem lock in would have just been all that much deeper. But Apple doesn't really think or operate like that.
Be really interesting to see how their approach evolves over the next couple years with sea changes happening all around them in this moment.