stat() is in the "Required Reason API" list. https://developer.apple.com/documentation/bundleresources/privacy_manifest_files/describing_use_of_required_reason_api
I do not use stat() in my app, but I use assembler instruction to invoke stat system call. And for a security purpose, I use its return value to check existence of some files and directories outside the app container. I use system call instead of API for a security reason.
Q. Do I have to declare that my app uses "Required Reason API"?