I works for a bank that is considering using an instant app (and AppClip on iOS) to provision a newly approved credit card with both our card App and Google Pay. I know you cannot take payments, but does that mean you are locked out of TapAndPay completely? Would you be able to provision a card in Google Pay from an Instant App?
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So after communication with Google Tap and Pay support, and trial and error -- the answer is yes. You can access TapAndPay; however, you can not recieve or make payments from an instant App.

Robert Sherman
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are you saying that Google said you can provision credit cards from Instant Apps? (and just not receive/make payments?) – w3bshark Feb 24 '22 at 06:39
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Yes and in release. You cannot make purchases -- yet -- although apple allows it in App-clips. – Robert Sherman Mar 30 '23 at 14:23
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Thanks for following up :) We were able to make a proof of concept Instant App with the TapAndPay SDK to add cards to Google Wallet. So, it's definitely possible! – w3bshark Apr 03 '23 at 13:03