I would let digital creators speak first on that one, but the short answer is, yes, that's exactly right. The current system.... I think many small creators would look at the point system and realize immediately that they would never be able to qualify and not even bother trying to work with that system.
We'd like to see it radically revised, but we have no indication in this bill from the government of how deeply they will do that revision and whether it will actually be accessible to all digital first creators in the future.