Alfred - Based on my testing, in 3.1 - both with standard event fees AND with price sets - if the user is given the option to select fee option(s) where the total value = $0, we do allow them to continue (submit) w/o filling in any of the billing fields (CC and billing address). AND we bypass interacting with the payment processor completely.
I tested this w/ PayPal Pro as the selected processor.
If you can recreate a configuration on the demo where we force user the enter billing info when the fee total is $0, please file a separate issue with detailed steps to recreate.
assigning for 3.1 verification