When the creation of databases is disabled for the virtual server owners, a text will show up saying "No more databases can be added, as you have reached your maximum of 0." based on the settings of the account plan.
However, you can consider it more a restriction than a count when you disable the option to allow the virtual server owner to add databases theirselves. If 0 is set in the account plan, the text shouldn't be displayed but replaced with an alternative text such as "No more database can be added, as this account does not have permissions to add additional database.".
It would also look more convenient as 0 doesn't know any minimum or maximum. As usual, added a screenshot of the text I'm talking about.