Rejected update without AppTrackingTransparency

Do you know if iOS app updates are already required to have AppTrackingTransparency request?
I thought that this message from Apple https://developer.apple.com/news/?id=hx9s63c5 means that ATT will be required early next year. But recently we have submitted update of our game (without ATT) and it was rejected with issue "Guideline 2.1 - Information Needed. .... Please provide the steps to locate AppTrackingTransparency in the app."
I asked in the reply about it, but no message from Apple since 2 days.

Previously, one week ago we have published new game. Build was rejected with the same message asking for ATT, but in this game we have ATT implemented (because we want to see how many people accept it), so we explained where it is displayed and it was accepted.
[Update] I've got reply from Apple:
"Regarding guideline 2.1.0, If your app does not include AppTrackingTransparency functionality, please indicate this information in the Review Notes section for each version of your app in App Store Connect when submitting for review."
The problem for me is even if I have the same explanation in review notes, they ALWAYS reject first and they approve when I answer in the resolution center with the exact same review note.
Rejected update without AppTrackingTransparency
 
 
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