If you are an iOS developer (a person who does not have a DUNS number) and you are writing an application for a company that wants to distribute the application for more than 100 devices, then yes, this company must register for iOS.
The program does require a DUNS number and contact for its legal department. The company must sign an agreement with Apple that they are not going to abuse the certificate. Misuse will distribute any developed applications outside the company without going through the application store.
However, what you can do is sign the application with your individual certificate of distribution of advertising and provide them with an IPA. They will then need to coordinate the IPA file with their internal distribution certificate for deployment.
The command is codesign -f -s {SIGNER-IDENTITY} "/Path for your .app file"
where {SIGNER IDENTITY} is the distribution of the iPhone: company, Inc., which they can find in the access to the keychain and Path for your .app file , is in your payload folder. Unzip your ipa folder and payload, you will find yourapp.app to look like this:
codesign -f -s "iPhone Distribution: Company, Inc." /Users/MyName/Desktop/MyApp/Payload/MyApp.app
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