Yes. If Apple takes the “we're not going to” stance, then this could be okay… but they've been doing that less and less, and they only ever really did that in the US / Australia. Apple just isn't trustworthy enough.
Also that since the system is opaque by design it’d be really hard to tell if details changes. Technically I understand why that’s the case but it makes the question of trust really hard.
For me, the big concern is how it could be expanded. This is a real and valid problem but it’s certainly not hard to imagine a government insisting it needs to be expanded to cover all photos, even for people not using iCloud, and we’d like you to add these signatures from some images we can’t show you. Once the infrastructure is there it’s a lot easier to do that.