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Below 100 CCU or 250 UD, you can still purchase Virtual Apps and Desktops subscription licenses in whatever quantity you like. The limits apply to universal (DaaS/Cloud) licensing only.

Thank you, @Daniel Marsh

Yes Citrix On Prem Term (OPT) is still an option for lower buckets sub 1k. And they did then also allow cloud provisioning with OPT BUT then later was finding out that was even limited to less than 1K users for cloud provisioning but nowhere could I find that noted or enforced.