Yes, I think an implementation may write arbitrary bits to an unnamed bit field. I think footnote 126 merely states the intention why unnamed bitfields of width larger than 0 were introduced:
An unnamed bit-field structure member is useful for padding to conform to externally imposed layouts.
So basically unnamed bit-fields have the same semantic as padding bits. You just can't rely upon their contents.
Allowing the implementation to basically ignore an unnamed bit-field when writing to an adjacent named bit-field a
greatly eases the handling of that field a
. The current value of the unnamed field doesn't have to be read and the write can be done atomically in one go. Just as for padding bits that might be contained in the structure.