Okay, this might be a non-issue: https://github.com/ChrisTitusTech/winutil/issues/2697#issuecomment-2403792309
To those that arrive here from any Youtube or Twitter posts, please know that disabling Recall via DISM works fine, and preserves the modern File Explorer (though some might consider this an anti-feature). CBS correctly disables it, and the disablement is preserved through reboots, just like with any other feature.
Edit: of course, the big problem here is that it’s still present (even disabled) and hence malware could turn it back on without you realising. Ugh.
About the only thing Google is right to be concerned about here is the timeline to enforce these changes - requiring them to be implemented within a couple of weeks does indeed pose a risk that something will go wrong or be missed (causing vulnerabilities). Other than that, I look forward to Google being forced to allow competition.