That's implying that it is actually off and not just pretending to be off, and that it requires a command to start recording instead of just constantly recording and only uploading when commanded to
Far enough down the threat model rabbit hole the real solution is just ditch the phone if you're doing anything mildly antigovernment. That at least forces them to do a bit more work to spy on you.
That's always one of the big issues in opsec/security discussions, we can always imagine a more motivated or well funded attacker but the likelihood of those being deployed against you change with the difficulty of implementing those methods.