I got the COC for my EQC 2022 from Iceland DMV. It says that My 2022 EQC is built with type cert. from 2001(GLC with 42 add ons). So that is why MB can sell you brand new EQC 2022 with NO SOS button. They will tell you that they are not mandatory to have SOS button in the car because of the Type cert(since 2001).
Although MB tells you that EQC is only 15% of a GLC.
SOS button is a safety issue not some add on, it can be the different between life and death.
I know that they also tells you that they were unable to provide your car with all the things that are needed for the SOS button due to Covid. But I would think that my car have all the wiring for it. So they can add that later on, with no cost for me(I wish

, ha ha, in my dreams)