I think it was a glitch, but I just got an error message installing macOS about it being out of date, and prompting to install in reduced security mode. This suggests that you can, in fact, do new macOS installs on Apple Silicon without phoning home (or if it fails).
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It's a security thing to avoid *unknowingly* installing vulnerable versions of macOS. Apple ultimately wants you to give consent to remove your machine security *through* a trusted environment to begin with.
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There is no requirement nor *way* of phoning home to ask about any specific custom kernel or OS. Apple doesn't know what custom kernel you put on your machine, or that you disabled security. All they do is certify that your initial/bootstrap macOS install was up to date.
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What I don't get is... how come the bootloader isn't required to be signed by Apple?

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It is. We cannot replace the bootloader. We can replace the OS (which we will replace with *another* bootloader), since the OS is allowed to be unsigned after you re-configure the boot policy to permissive security.
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