You are completely mis-interpreting the EU regulation, nobody requires a PIN code for the User Interface when starting a device at home. What are you protecting against with it? Against the users?
Absurd.
Article 3.3 (d)** – Radio equipment does not harm the network or its functioning nor misuse network resources, thereby causing an unacceptable degradation of service.
Article 3.3 (e)** – Radio equipment incorporates safeguards to ensure that the personal data and privacy of the user and of the subscriber are protected.
Article 3.3 (f)** – Radio equipment supports certain features ensuring protection from fraud.
All of these are backend level modifications to how you handle network traffic, encryption, where and how you store data and manage access to it. Any half-decent software developer can handle this in a completely transparent manner, through the already EXISTING logins you have on your device for the Rose account for example. You MAY add a PIN feature, but it changes absolutely nothing on YOUR compliance requirements. It’s the same concept as with a phone - the user can chose to have a PIN, or they can remove it entirely.

