iOS promotional code eligibility

I am implementing promotional codes for auto-renewing subscriptions in my app. I need to create the codes and have them link to a discounted auto-renewing subscription. So my normal 1 month subscription is $24.99, I would like to offer users (new subscribers and existing/expired subscribers) the ability to enter a promo code that discounts the price of the first month to $4.99, then $24.99 after the initial first month. All users, regardless of whether or not they have has a previous subscription or not should be able to use this code for this discount. From what I am seeing in documentation, promo codes are only available to users that have had a subscription previously? Currently I am receiving the response "Offer Not Available" with the error: <SKPaymentQueue: 0x2815f0d60>: Payment completed with error: Error Domain=ASDServerErrorDomain Code=3904 "Offer Not Available" UserInfo={NSLocalizedDescription=Offer Not Available

I simply do NOT understand why apple engineers have to make something that should be somewhat straightforward, be SO COMPLEX, then when you try to figure out whats going wrong, no meaningful error to troubleshoot. WTF I have tried this on users that have had a previous subscription and still the same error.

iOS promotional code eligibility
 
 
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