In the end, the file system doesn’t exist in isolation, it is there to support users, and most of them won’t care how many bytes “é” takes to store.
Unix, by not even defining the way to interpret the bytes of file names (one can’t even assume that names consisting of only bytes that correspond to ASCII letters and digits should be interpreted as ASCII) makes it impossible to show file names to users. That’s insane.
At the FS layer, I think that's better. Makes things simpler for programs. For non-techie humans, unicode can be normalized at upper levels, like the GUI file manager or toolkit library that does save dialogs, etc.
That's if humans being confused because of lack of normalization of unicode is a real practical issue and not just something that can happen but never does.
Many fun times trying to copy/move/remove a file and not being able to do so because the input and name stored on fs is actually different bytewise...
Seems like linux has the only sane filesystems not trying to mangle paths at all.