Steve, what a lovely person you are! Hope you're keeping well during this strange time. It's my understanding that the rules only apply when a 2-way transaction is involved (such as if you were to be selling the keys, rather than handing them out at no cost). So how you decide to offer them out is up to you. :)
This thread was added on March 20, 2020, with posts from [Fatshark] Julia.