Earlier quoted context omitted.
They can. But the problem lies with Browsers (looking especially at Firefox) just ignoring that. The technical aspects of DoH (or DoT) are fine.
Mozilla provides a clear policy for how you get your resolver onto their list. US ISPs (the DoH resolver is only enabled by default in the US) could obey that policy and apply to be added to the list. But it seems like none of them have done that. Maybe the policy terms are objectionable? Let's see: "Only aggregate data that does not identify individual users or requests may be retained beyond 24 hours." But how will…
Also it is questionable why a free service would be better then a paid one. If one assumes that the ISP is evil, DNS providers are not suddenly less evil.