ICANN iirc still has a group that can tell ccTLD registrars to get their shit together and if the company also handles gTLDs (which iirc freenom does), they can

ICANN iirc still has a group that can tell ccTLD registrars to get their shit together and if the company also handles gTLDs (which iirc freenom does), they can still make that a bureaucratic nightmare for them. It's not one of those things where they can outright say "you can't do that", but it is one of those things where it's "if you don't cooperate we'll make your life hell in other ways".