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Most of your points seem to be spot on from what I understand as well. However, I believe that the GDPR requirements can and should be baked into Lemmy itself. This would prevent the fragmentation you mentioned. A guarantee of removing user data as requested while federated plus a guarantee to remove stale user data while defederated since requests won't get through in that case. That would "just" leave the list of processors. This one can be very tricky because you are not just sharing data with your home instance and their federated instances but also with the federated instances of those federated instances. The home instance has no way of learning about the 2nd degree federation. I have no idea how to get the network of data sharing GDPR compliant and I think this is the mich more complicated part that your proposal also suffers from.
Yes, I agree. This use case likely wasn't considered when the law was written. We'll see how things turn out in the future because at some point we will have enough very knowledgeable people regarding GDPR in the community who are willing and even keen on steering the project in the right direction towards compliance.