The platform problem will likely show itself regarding redemption. If you are redeeming a fiat denominated thing for sats, it’ll be considered a sell of BTC for dollars, making you an “exchange.” I don’t know the specifics but I feel this would creep up at some point.

The only way I’ve thought that an sats based gift card system could work is if people pay sats for a sats denominated gift card. As long as the denomination doesn’t change I think you are good. But so much of that is murky that I honestly don’t know outside of what I got from some conversations with DeepSeek.