Why do I have to have a card on file to download free apps

• You must have a card on file when you set up your account. It is used to verify your identity and your country.
• You must have a card on file if you have any apps with subscriptions, or apps that have in-app purchases.
• If you have no active subscriptions, no apps that offer subscriptions, and no subscriptions that have been canceled in the past year, and no apps with in-app purchasing, you may be able to remove your payment method.
• Even if you are not required to have a payment method if you do have one it must be current and valid.

Here is additional information from Apple→If you can't remove a payment method from your Apple ID - Apple Support (PH)

bebe8484 Said:

"Why do I have to have a card on file to download free apps: Why can’t I download free apps"

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Why?

This is because even in free apps, there are links to payable items.