Maybe you're referring to whether or not the core ability to wake from sleep can be disabled? I've never tried to do that, so I can't say.

In my experience you can reliably stop windows from waking in unwanted ways. I usually disable everything except input devices (keyboard, mouse).

No that's not it. The issue is actually pretty involved, there is a LTT video on it, this is the bit I'm remembering: https://youtu.be/OHKKcd3sx2c?t=475

Ah I see... you can disable network waking, also the ability of Windows Update to wake the computer. That, combined with disabling wake in other areas, solves it on various Windows computers I've tried it on.

I guess it's possible that all of them were defaulting to S3 sleep though, I never checked.