Processes in Microsoft 365 for setting up Office apps, redeeming product keys, and activating licenses.
OK, I (finally) just got a look at the current MS License Terms for Office 365.
Yes, the 365 license terms no longer allow you the right to transfer the ownership of the subscription. (on the other hand, the one time license terms still allow the right, MS has simply made the process almost impossible).
The "owner" of the Office 365 subscription is not established by MS until activation is done. So it appears as far as MS is concerned you can give the "free" subscription to someone else before the activation. Unless the subscription is an OEM equivalent of 365 Personal (no mention of that kind of creature that I've seen so far) which the OEM has to partially activate to specifically associate the hardware to the license before it can be activated by the user, I don't see how MS can track the 365 subscription back to a specific hardware owner.