After posting in the Windows Phone Development forum, I received this answer:
OnUserAction needs mobile operator support in order to use since the app will need access to the Secure Element on the device.
There is some more information about the Secure Element API and the use of OnUserAction here.
Essentially, control over the Secure Element API lies with the mobile operator:
The use of the Secure Element API in an app requires a specific type of SIM card provisioned by a mobile operator on phones that run the app. If you are collaborating with a mobile operator on an app that uses mobile payments, contact the mobile operator for the information necessary to use the Secure Element API.