Keychain ACLs and evaluatedPolicyDomainState

If on iOS an app protects a keychain item with an access control list that specifies .biometryCurrentSet in its SecAccessControlCreateFlags the app loses access to the item if the set of currently enrolled fingers (for Touch ID) or the currently enrolled user (for Face ID) changes - which corresponds to a change of the evaluatedPolicyDomainState.

We have users reporting loss of such items even though - as they assure us - they have not touched (no pun intended) anything under "[Touch|Face] ID & Code" in Preferences.app.

Is there another reason why an app may lose access to such items?