That’s my interpretation as well, and seems to fit with the not-quite-so official response from Asobo regarding the new driver and DX12 memory optimization automatically enabling. Using DX12 with the latest patch, performance is roughly back on par with the first SU10 beta build 1.27.9.0, which was by far the most impressive build in terms of DX12 performance.
People should be aware though that DX12 + the new memory optimizations will use a lot more VRAM. If you’re already near max capacity of VRAM using DX11, you might want to think otherwise about using DX12. Conversely, you can also reduce texture resolution by one level to reduce VRAM consumption.