This would argue that change of ownership of a domain should be treated equivalently to creation of a domain. Of course, given GDPR (or rather how the registrar

This would argue that change of ownership of a domain should be treated equivalently to creation of a domain. Of course, given GDPR (or rather how the registrars have chosen to interpret GDPR to reduce their legal liability risk), ownership information is now unavailable, so all you have to go on is the registration modification timestamp. Unfortunate.