The entrance pupil position will also vary by changing the focusing distance
Hi Frank,
In general that's correct, which is why I tend to calibrate for specific scenario's (e.g. landscapes focused on 3 metres, longer distances will not exhibit much parallax anyway, or close-ups, or telelens/'gigapano' work).
However, also here, in particular internal focusing (lensbarrel keeps the same length) may leave the more frontal lens elements (and thus entrance pupil) relatively stationary, while shifting the rear lens elements and/or groups fore/aft.
One just needs to test for particular lens design.
Cheers,
Bart