https://developer.android.com/about/versions/11/privacy/stor...
Asking for access to root directory is not allowed. Asking for access to "Downloads" or app-specific external directories is not allowed either.
There is an escape hatch:
https://www.xda-developers.com/google-file-manager-devs-subm...
but it is intended for dedicated file manager apps and requires an application to be manually reviewed by Google. Which hopefully means, that banks and other shady organizations won't qualify.