Also, if they're signing any Linux distro's shim loader, shim allows a physically present user to enroll their own key or disable secure boot. See method 3 at https://wiki.ubuntu.com/UEFI/SecureBoot/DKMS .
(I don't actually know if they are signing any Linux shim for ARM - https://wiki.ubuntu.com/UEFI/SecureBoot/Testing#UEFI.2FSecur... implies no. Which means you can't use any version of Linux on it, unless they change their policy.)
The rest involve changing EFI variables, yes, but my impression is that "Custom Mode" refers to a UI in the BIOS which permits you to change the variables, and those variables are always writable by code running in boot services. The requirements say, "On non-ARM systems, the platform MUST implement the ability for a physically present user to select between two Secure Boot modes in firmware setup: 'Custom' and 'Standard'." Nothing I'm suggesting involves going to firmware setup.
I've got the full disk encryption working with luks/grub (you do have to unlock the device twice, one for grub to read its stage2 and one in the initrd for the kernel), I just haven't gotten around to trying to re-enable secure boot.
Otherwise, why have the antitrust laws at all? The dominant market players provide useful services, why should we care about the minor players? (Not only in operating systems, but in general).
The solution is to attach a SPI programmer (eg a RasPi) and flush the UEFI variable store. UEFI will reset to factory defaults, incl Secure Boot.
The complicated part of that is opening the device.
I don't see why it's not actual security.
And fair's fair, Microsoft was the one that pushed UEFI so hard.