Apple’s fs do guarantee the paths are correct, as in, valid whatever encoding this has nothing to do with glyphs.
APFS also does not perform any normalisation while HFS+ uses a custom variant if NFD. While HFS+’s normalisation has its issues and critics, APFS’s lack of normalisation is probably worse: https://eclecticlight.co/2017/04/06/apfs-is-currently-unusab...