Yes, I see the argument that if you go to that point you might as well just use emulation. However running mixed 32bit/16bit code (Windows 98/95) becomes problematic just because of performance reasons. DosBox does well, but good luck supporting games for the Pentium 3 era that still used 16bit libraries because of course they did. (16bit Installshield was so common going into 64bit that MS just has code to replace it so 32bit applications can still be installed despite having a 16bit installer)
Seems like a bad tradeoff, and part of a slippery slope towards a completely locked down system, where writing your own code and getting it to run on the 'bare metal' is flat out impossible.
Unless you're targeting S/360, but even there XA and newer made it a bit more complex.
Sometimes I wonder: if UEFI instead used ELF format, ext2 filesystem, and somewhat less complicated API (let's be honest: UEFI API is pretty straightforward if tedious), would people still complain about such dependencies? Or would it be deemed to be "fine" since it's not Microsoft technology even though it still would require one to use a multi-megabyte toolchain?
FAT originally only can do 8.3 filenames, but take a look at this to see what they hacked on top: https://en.wikipedia.org/wiki/Design_of_the_FAT_file_system#...
This is all the legacy shit you now have to implement when you want a so-called "legacy-free" boot. Infuriating.
I could easily read NTFS with hexeditor, calculator and pen&paper. Trivial even (most annoying part was the run length packing in 4-bit nibbles).
I gave up trying to read ext's cylinder-oriented mappings.
And FWIW, everyone has a read/write driver for FAT with LFN (and UEFI generally avoids names outside 8.3 just in case), using a different filesystem would lead to issues with OS support.
PE itself isn't really that much of legacy cruft, especially as far as it is used in UEFI (sure, you have the "program not for MS-DOS header", but that's useful for the rare case someone tries to open it under FreeDOS).