Officially, one should not use KERNEL32.dll for instance but go via crt. In practice, most interfaces are stable.
It just causes one big headache that a DLL can't simply return a pointer and have the caller use "free", because malloc/free can be incompatible across modules.
This just led to the COM standard, featuring reference-counted objects that don't care what underlying way was used to allocate the memory. For the situations where you do need memory buffers, COM enforces the use of CoTaskMemAlloc/CoTaskMemFree.