It is not possible to make app via your API for nfc.
You need to assign token (card number) and trx should be sent to Bunq via MasterCard. A lot encryption is used in this process so it should be done by Bunq.
While I understand why you wanted to switch tap and pay off, you could do it in much nicer way.
First add all EEA countries to google pay, maybe support also samsung pay and then disable tap and pay with announcement.
Currently Malta was left out.
I already move than half year not able to use any NFC solution.
Tap and Pay was not working for me.
FitBit (opened as separate thread) as well not working.
You definitely need to review you implementations and policies around NFC solutions.