This would be less of an issue if there were an explicit regulatory mandate saying "businesses larger than X may not limit any consumer capabilities for interacting with their business in such a way that it can only be accessed by proprietary applications running on locked-down systems that a user cannot modify, control, or install their own software on. Offering to have a person handle that functionality on their behalf does not constitute an alternative to functionality made available via such an application". (With appropriate clear definitions for "locked-down", and other appropriate elaborations.)