Unlike for Zigbee, ZWave or ESPHome this actually seems to be true for Matter devices. Not only that full functionality of a Matter certified device can directly depend on cloud/app/account 
But the initial commissioning (before being able to make any use of a matter device) requires cloud to allow provisioning. That part might be circumvent as described here: Guide: Bypass matter attestation verifier
I expect the default matter Implementation shipped wit HA to actually “respect” the DCL because otherwise they would violate the matter specification? 
