The processing behind Wires and Outline is different, in a way that made Wires pretty much unsusceptible to having to have noise that gets cleaned up. Wires didn't really "render" the same, as it was calculated from the geometry, but Outline is calculated by firing rays into the scene, ie, what normally happens during rendering. As such Outline was NOT meant to be simply a more refined Wires - it is intended as a whole different solution, to achieve different things.
Noise as a measure can only ever account for "percentage of noise present across the whole image", that is precisely what it measures. With a simple plain material outside of the Outline, that simple plain material will clean up and give a tiny fraction of the image left with noise remaining. This would be similar to having a small object against a single color background, another situation where Noise is not necessarily a good measure to use. Since these situations exist, this is why Pass and Time limits are still in place as options, because Noise sometimes is not that suitable.
If you want to use Noise, you just have to lower the target significantly compared to what you would usually use. You can either use that super low value as your target, or you could do it once to find out how many Passes it takes to reach a clean image, and then use that Passes value in all similar images, knowing you won't be "wasting render time" by doing extra unnecessary passes.
So, what you are seeing here is not a problem or limitation of the Outline, but a limitation of Noise as a measure of whether an image is visually clean enough yet.
PS I guess another way to calculate a Pass / Time value would be to do a Noise target render using render region, narrowed down to where there is a high prevalence of the Outline result, that way the Noise value will be more of a measure of "how much noise is there in the Outline part of the image only", and then you can use that as the Passes value for the entire image, again letting you know Passes or Time has not been set arbitrarily too high.