I'm not saying the author's wrong, but would Apple require FCC approval for a device they don't ever intend to sell?
I suspect that apple my not make this into a product but whomever is making the mechanism for them may license it from apple and offer it as a product.
The picture of the circuit board has an HID security systems logo (shown below) on it. There is something fishy here. The only reason Apple would have that logo on their board is if HID required it for use with their cards or they are using an HID board.
Maybe it's for compatibility for various reasons such as: Fire Department access, guest and contractor passes, etc. Much easier to buy a batch of HID passes and assign them for those. Employees can use their Watch or iPhone.
I'm pretty sure Apple would prefer NOT to use COTS software because of the number of backdoors (haha) that are possible in them. I don't think any of the COTS door systems are open source, and it'd probably be easier to just write from scratch than audit some really old code.
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I suspect that apple my not make this into a product but whomever is making the mechanism for them may license it from apple and offer it as a product.