Maybe not complicated, but unorthodox. A developer who is not familiar with the correct design patterns may, for example, create a dialog using a FrameworkWindow instead of a FrameworkDialog. In that case the framework can not provide any automation, because the developer is not following the guidelines.

I would argue that any sufficiently powerful framework also provides more ways to diverge from the "proper way", so it puts more pressure on the developer to actually study and understand the framework design patterns.