requirements for provisioning an app on android 13

I could be wrong about this so I'd like others to chime in as well but my understanding is that Google is pretty restrictive these days about letting anyone declare Device Owner privileges. They are pushing people away from Custom DPC bit by bit toward Cloud DPC and don't seem particularly keen or interested in letting new entrants leverage this approach without their approval. Even though you might be attempting to just leverage this approach for internal company devices Google might not allow it due to possible nefarious use of that dangerous elevated permission level or also because they generally pushing people toward Cloud DPC anyway. I think their argument might be you're better off using a purpose built EMM to achieve the goals you're looking for, otherwise you're reinventing the wheel a bit. That's at least how I understand things but I'd be curious to hear other perspectives.