I would think this is intentional but for some options like "verbose" the flag is set and for others it is not.
For example in our default GnuPG VS-Desktop gpg.conf we have forced the compliance mode but it is reported as.
compliance:16:2::1:1::"gnupg::"de-vs
For read only it would need to be > 128
Keyserver is somehow reported as no change if forced but then with a wrong value.
keyserver:128:0::1:1::::1
for an entry with an URL.
This was tested with 2.2.34-beta22 and latest libgpg-error on linux.