EX Raids - EX Raidpass only after lvl 1-4 raid?

Today The Ex Raid passes rolled out in Belgium.
My first remark is that all passes are distribued to people who did a lvl 1 - 4 raid.
Is it true that, if you only did legendary raids, you can’t receive a raidpass?
Just the 4 seperate people i met today got it from a lvl 4 raid or below.
I hope you guys have a bit of time to answer my question.

Kind regards

Possible.

The legendary raids don’t count toward your progress in your medals either.

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I only did legendary raids at the gym I got an EX pass for. So is completely random as it seems.

Not true…the gym I got an EX pass for I did 2 raids at that gym and they were both legendary raids