This is an artificial requirement. Something MS likes to do to make people upgrade to newer versions of windows, and its less work for themselves by only making it for one OS. They did the same thing with DX11 and DX10.
This could be the case, and quite likely it is. However, it may be that it is how Microsoft is providing for the more minimal abstraction with regards to resources. AMD was able to do it without any such requirements because their Mantle/GCN interaction isn't hardware-agnostic, it requires their driver. With that, hardware-specific APIs are possible for sure. APIs that are hardware-agnostic, that perhaps requires some fancier tricks.
We'll know for sure once Vulkan is released and if vendors are able to support that on any version of Windows. I suspect they will be able to do so, but then again, it's no guarantee that D3D 12 for some reason doesn't truly require WDDM 2.0. Why? Because Vulkan support is still very much dependent on the drivers, so coding Vulkan support might just require more work at the driver level than D3D 12.
Again, it's almost surely just a platform requirement to advance adoption rates, I don't think there is much in the past to dispute this as their M.O.. That said, I do think the requirements moving between XP and Vista (D3D 10?) were likely honest, as the kernel stack was almost entirely redone between NT 6.x and NT 5.x.