Yes, and the other thing you have to do for this to be applicable to you is choose to be an "operating system provider", as defined in the law.

If you don't want to write, hire someone to write, pay someone to provide an implementation that has already been written, or acquire an implementation already written that is available without payment, such an API, you can simply choose not to do what is defined as being an “operating system provider”, and no obligation attaches,

No one is putting a gun to your head and forcing you to do labor to write code for an API.