My newsstand app only offers one subscription and it is free. I know newsstand apps will be rejected if they do not use iTunes Connect subscriptions.
Will apple care that I never validate the receipt. The only thing I use the receipt for is to determine if they have subscribed or not and if they have then I register for push notifications.
Also, it doesn't seem like the concept of an "issue" as in the issue information that is posted to iTunes Connect is strictly necessary....