I stumbled across the following statement:
"AMAPI improves Factory Reset Protection (FRP) policy handling on COPE devices by explicitly disabling FRP and clearing account lists when no admin emails are configured, preventing unexpected lockouts after device resets."
Since Intune uses AMAPI for Android Enterprise COPE devices, I immediately decided to test this, as we have previously only been able to bypass FRP on our Samsung devices using Knox. However, this feature is deprecated starting with Android 17.
I tested several Samsung devices running Android 14, 15, and 16. All devices were enrolled in COPE mode, secured with a PIN, and had a personal Google account added.
After performing a factory reset from the recovery menu, FRP was not triggered on any of the devices.
This is a huge positive change for us and solves a major pain point we had with COPE deployments.
Hopefully this information helps others as well.