Odd choice and poor optics (just limit the number of times you can enable and add a warning screen) but I wouldn't assume this was intentionally evil bad faith.
I’ve seen reports in the past that people found that syncing to the cloud was turned back on automatically after installing Windows updates.
I would not be surprised if Microsoft accidentally flip the setting back on for people who opted out of AI photo scanning.
And so if you can only turn it back off three times a year, it only takes Microsoft messing up and opting you back in three times in a year against your will and then you are stuck opted in to AI scanning for the rest of the year.
Like you said, they should be limiting the number of times it can be turned back on, not the number of times it can be turned off.
Not trying to say that you could have prevented this; I would not be surprised if Windows 10 enterprise decided to "helpfully" turn on auto updates and updated itself with its fun new "features" on next computer restart.
And even so, let's say they didn't use Windows — I'd still expect the same rigor for any operating system update.
Then you are hopelessly naive.