Hi,

Thank you for reaching out to the Google Ads API support team.

To create accounts within the manager account it should satisfy the following 
criteria:

has spent more than $1,000
has a history of policy compliance

For more information, please check this help center article on how to create 
new manager accounts from you manager account.

Hope this clarifies! Let us know if you have any further questions.
This message is in relation to case "ref:!00D1U01174p.!5004Q02vFViT:ref" 
(ADR-00265498)

Thanks,

Google Ads API Team

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