NTDLL isn’t some higher level library. It’s just a series of entry points into NT kernel.
I argue that NT doesn't break its kernel ABI.
[0] as long as you don't use APIs they decided to add and remove in a very short period (longer read: https://virtuallyfun.com/2009/09/28/microsoft-fortran-powers...)
...and you go on to not disagree with me at all? Why comment then?