I kinda get your point that Apple will have to devote some more resources, but it will only be slightly more: All the API are already there and being used by Apple apps privately and they just have to make it open to everyone. That's not really a huge overhead for someone of Apple's size - they'll just need to publish / update documentation and increase their developer support teams and that doesn't cost 10's of millions of dollars (which is again peanuts for Apple).
Private apis are nothing like public. You can’t just document them and toss em out the door because Private means you can change and break them every release without concern because you control all the consumers. You can also start using incomplete ones before the contract is solidified. Public means they are in use and shouldn’t change much, and if you do you need to announce a deprecation and then slowly deprecate. Not that apple has to do that but generally that is the rather large difference and you know the moment they break one everyone will be scream at them for that.
This is really not how it works. Private APIs are usually poorly designed for general use — safeguards for excess power consumption, etc, often don’t exist.
Many things will need to be rewritten; this legislation will result in significant delays in shipping new end-user features, if Apple doesn’t simply pull out of the EU, since the EU is demonstrating with this legislation that they don’t care about end-user privacy/security.
> This will have an extremely high cost to Apple if it’s implemented.
Come on, do you really expect us to be sympathetic to a trillion dollar company if its profit margin reduces? (Which any way may not happen - realistically, they'll just pass on the cost to us consumers).