Windows has an extensible model. It's a different approach from most (all?) other OSes. It offers a different set of features.
Sure, AV could perhaps be done in a different manner that would be more effective/faster, I can't comment on that as I lack the insight required -- only MSFTies that work on kernel code could respond in any authoritative way.
But I'm not particularly knowledgeable either on this topic, just a (forced) consumer of the operating system with the occasional reading on the side
FAT[32] does implement minifilters.
https://learn.microsoft.com/en-us/windows-hardware/drivers/i...
https://www.osr.com/nt-insider/2019-issue1/the-state-of-wind...
I guess my mental model on this was just lacking/simply wrong.
If you want to know more, grab the book Windows Internals.