Sure, they could probably push it through into any iOS, but all currently available documents claim it’s a iOS 15 feature and presumably there will be lot’s of new legalese like specifically for those new features.
You're not wrong about Apple's messaging around this. I was specifically responding to your claim that pushing it to iOS 14 would require modifications to the EULA. It would not.
There are a couple things that are nagging me though: 1) Apple has loads of legalese for each and every feature and 2) it sounds like they could just cut all that down to two points that you cited and be golden.
I definitely see your point and I guess we can leave it at that until a lawyer can explain this...