Other inits aren’t even commenting, let alone complying.

This would be a fair point, if systemd wasn't more than an init system. While a service manager (init system) is included, systemd is a system manager. OpenRC, runit, and other init systems do not need to comment because their only task is to mount the necessary file systems, setup the device manager, and start daemons1. systemd as a system manager not only needs to manage services, but it also needs to manage devices, logs, the hostname, etc.

Does this mean systemd is not bloat? Not at all, but it is not as fat as you think it is. Your system could honestly be fatter without systemd if you try to replicate everything it does with external applications. Does this mean systemd should also be justified to add an optional field for your date of birth? I guess I would say it's weird on it's own. However, given the context, I believe they are doing what they can.