This is making a mountain out of a molehill. There's nothing to suggest any pre-conditions for deleting an account have to be removed, simply that it must be possible to "initiate deletion" from within the app.
Then you're defeating the purpose of the requirement, because the scummy scam service will let you "initiate" deletion but to actually carry it out you still have to call them and wait on hold for sixteen years or come show your ID in person at their offices in Northern Alaska.
Frankly, this would still be a good start compared to the norm today: You can't even find information about account deletion from most mobile apps, let alone initiate the process.