Opening the holes for the registry files is not recommended. When adding and removing users, the operation involves security operations that are best performed when UWF is disabled. There is no change in UWF between Windows 10 Enterprise LTSB 2016 and Windows 10 Enterprise LTSC 2019 in this area.
A possible solution is to script the operation. The admin adds / deletes a user via a custom program, and the behind the scenes a script could take the information, disable UWF, reboot, make the user change using net.exe and re-enable UWF and reboot the system. Same process could be performed for a User changing a password. I know this is not ideal, but with all the operations that take place, it comes down to the only option.
Can you share a little more on what the device is or does?
-Sean Liming