Because it doesn’t specifically call out allowing users to bring their own content but does call out allowing developers to distribute their own makes me skeptical that Apple would approve a stand alone emulator with out games (because there is no point to the app) and wouldn’t approve an emulator with games that breaks copyright, maybe the way around it would be including some homebrew ROMs with it.

They haven’t removed ScummVM in the past so it could be possible but based off of other developer experiences I have my doubts how these rules will be enforced