It has been this way for a long time in Sweden. However on the pro-side, it also means that someone that do not want SRS but stillwants to be recognized as female, will be recognized as such if having an Orchidectomy.
However the law demanding irrevisable infertility is being looked through as we speak.
Reminds me, by the way, of a ->-bleeped-<- for some years go, that had fought the Government about being allowed to change to a fully female name, despite being "only" a ->-bleeped-<-, as she was living fulltime in a female role.
Eventually, she actually won the issue.