DRM stands for digital rights management, meaning it has to contain a software that restricts a users ownership and what they can and cannot do with the product they bought. The game does not contain any such software, not Securom, Starforce or Denuvo. You said they're being two faced but if that's the case then why is the game DRM free digitally? Where's the software that prevents license transfer?
While I think this is a really minor issue, a one-time activation done via a file is essentially a small form of DRM.
"Digital Rights management" is exactly what it implies, it's any technique applied to allow the manufacturer to control users access to their product. This techniques don't need to be any specific software.
By not giving a file needed to play the game they are doing exactly that, they're assuring that anyone that gets access to the game earlier can't play it.
Withholding files and requiring an online conection is a DRM practice that's been done before by both MMO games and single player games.
As an example, Assassin's Creed 2 needed persistent online connectivity because the local game didn't have all necessary files and the game would stream those files as needed. No specific software needed, yet it's still DRM.
Or a closer example to what CDPR is doing with Witcher 3, Steam pre-loading, in that situation the player even has the entire game files locally already, but the files need to be decrypted for the game to be playable. That is also a form of DRM.
This is the same idea and technique but applied at a much more basic level, since it only requires you to download once single file once to make the game playable.
It's essentially harmless if you have internet access, but it does disallow users that don't have internet access from playing the copy until they get internet access again.
Does requiring a downloadable file mean I cannot do with the game whatever I want? Does it remove ownership? Does it revoke any licenses? Because that is what DRM is in the end controlling ownership and licenses. In the end I will be able to resell, lend and borrow any physical edition of Witcher 3 on PC, install it and give it to someone else.
It means that you cannot play the game until you activate it. So yes, you cannot do with the game whatever you want until you fulfill this one, minor, condition.