Feels like a no win situation for Google. Do you show results that people don't want to pay for, or do you not show any subscription needed results and people accuse you of monopoly behavior only showing sites running adsense.
Right? It doesn't have to fully elide the result even. If the top of the SERP said "3 results hidden because they are paid sites on your non-subscribed list" I would appreciate the info.
They had a simple rule that they index what users can see and if you try to cheat your way around that you get ranked down. Sticking to that for everyone would have been an iron clad defense against monopoly accusations. Instead they chose to help certain corporations (or at least corporations with certain business models) present different content to the bot and users.