The risk is in trying to keep compatible with the Linux Kernel, when not part of the Linux Kernel dev team.
If ZFS was a module within the Linux kernel source tree, Linux kernel devs would keep it in mind when making changes to the Linux kernel's APIs. They wouldn't make potentially breaking changes to that API, or replace APIs with ones that can't be made compatible with ZFS at all, without considering the effect it would have on ZFS. The Kernel devs have to take the whole tree into account, including all the modules.
But since ZoL is not part of the kernel, and is instead a separate independent module that gets loaded into the kernel, the ZoL have to play catch up. Instead of Kernel devs working with them to make sure things stay compatible, or giving them a heads up when something needs to be changed for a new version, the ZoL team is on the outside, trying to make sure they don't get boxed out of the Kernel API.
It can be a tenuous position to be in. For a more everyday example, look at the Firefox and Chromium browser updates. For Firefox Quantum they completely revamped their extensions system, making all existing extensions worthless. Either the extension devs rewrote them with the new API, or the extension is just gone. Similarly Chromium is changing its API for how extensions can interact with the DOM and networking, which would make Ublock unusable. If these features were officially part of the browser or official extensions, the browser devs would work with the extension devs to make sure things stayed working; instead the extension developers need to keep up or watch their product die.
If the Linux Kernel completely changed its module API, and ZoL was caught flat footed and needed to make substantial rewrites, what would the projects backers do? Would they commit the dev time and resources needed to make those changes, or would they compare the benefits of ZFS vs the competition -- solutions based on btrfs or LVM, both built into the kernel -- and decide to jump ship before committing more time? That's where the danger really lies. If the Linux Kernel makes a serious breaking change, ZoL's supporters might double down to fix it, or they might just cut their losses.
And while there is an official way to integrate external filesystems into the Linux kernel, FUSE, it's extremely slow compared to Kernel native modules. There was a userland FUSE implementation of ZFS, and there's a reason it's fallen out of favor. ZoL is significantly faster because of its direct kernel extension, but it's playing with fire by not being part of the kernel tree itself.