There isn't a requirement to create a Microsoft account, either.
Maybe someone found a script/custom installation image, but the previous posters point about it being required stands for that one SKU at least. (I hope that there's a EU version that one can acquire in the future that gets around that, but I don't know if the Account requirement falls under the current legislation.)
I read things will improve next year thanks to the EU, though: https://arstechnica.com/gadgets/2023/11/europeans-can-soon-s...