I don’t see it that way. I would rather have a browser based, one-off tool that can generate a .pkpass served up for local “installation”, not installing an app that is necessary to separately manage the passes separately and very well could be tracking its users.
Well for this particular functionality whatever you use (website, app, etc) must have a valid apple developer certificate, so either the website must be up, the app's backend server must be up, or an offline app's bundled certificate must still be valid. All of these things will eventually stop being true regardless of the form the app/website takes.