Well, lets look at the BITE model.

Behavior control: They do set up a system of rewards and punishments for certain actions. Speaking about how lovely being trans is gets you rewarded, questioning things gets you punished. They force you to act "appropriately."

Information control: They intentionally hide arguments and facts that go against the organization's arguments while spreading information that does not need to be true if it supports their arguments. They lie to you in order to influence your thinking.

Thought control: If you start questioning the organization or whether you belong in it, you are swiftly reassured that the organization is never wrong and that you are absolutely a part of it.

Emotion control: Members of the organization are made to feel as though you can only be happy by being a member. Evidence that the organization is not making you happy is discarded and explained with the excuse that you aren't doing enough with the organization, that you're still holding on to outside thoughts and doubts that are holding you back from happiness. You are made to feel guilty if you do anything against the organization.

I'd say this scores pretty high on the BITE model with just a quick look at the 4 major areas. The organization controls your behaviors, information access, thoughts, and emotions for the benefit of the organization and the detriment of the members and their free will. There is very much an "us vs them" mentality to discourage seeking outside thoughts, opinions, and arguments that do not come in the form of an organization approved strawman and they will shun or exile ("cancel") anyone who dares to betray the organization.

Comclusion: It is highly probable that this is indeed a cult. It may not have as clearly defined a leader as a tradtional cult, but the ideology alone does all the leading it needs