Microsoft literally can not apply to Shutdown law, since its account system is entirely cross-platform, which is NOT covered by "Teenagers Protection Act" (which only covers PC).
"Teenagers Protection Act" is NOT designed with Cross-platform play at all. (Mobile games are not affected, but PC and Console games are affected) Therefore, posing Microsoft at awkward position between applying one or not.
Also, Microsoft can not afford to add support for Shutdown Act either. Since this is a global account system change. (Not like Ministry of Gender Equality and Family persued.) Also, usually in console network games, game developers uses their own servers to connect them on the multiplay. Microsoft only does provide account system for Xbox. therefore, every single game using Xbox Live should be re-programmed with Shutdown Act in mind.
(Also, considering Xbox Gamepass which also provides Indie-games, It is very unlikely they can afford to implement patch for Shutdown Act.)