I think this argument is cogent, however it is not compelling. One of the reasons it is not compelling is the evidence before that Royal Commision that many many times, for whatever purpose, these evil deeds were the subject of confession (as many as 1500 times in the case of one offender) with seemingly little protection for the victims. Clearly the practice of confession meant something to the transgressors, and the Church in this way supported and helped the transgressors whilst being deaf to the cries of the victims, and denying them justice.
In the end the Church acts as the protector of the institution and its agents, rather than the protector of the vulnerable and the innocent.
I do not accept the argument that the Government has appointed itself an expert on religious practice, and neither has it sought to change the sacrament of confession, but rather to ask the Church to stand up for the victims.
The way and means thereto is; First, to examine your lives and conversations by the rule of God's commandments; and whereinsoever ye shall perceive yourselves to have offended, either by will, word, or deed, there to bewail your own sinfulness, and to confess yourselves to Almighty God, with full purpose of amendment of life. And if ye shall perceive your offences to be such as are not only against God, but also against your neighbours; then ye shall reconcile yourselves unto them; being ready to make restitution and satisfaction, according to the uttermost of your powers, for all injuries and wrongs done by you to any other; and being likewise ready to forgive others that have offended you, as you would have forgiveness of your offences at God's hand; for otherwise the receiving of the holy Communion doth nothing else but increase your damnation. Therefore if any of you be a blasphemer of God, an hinderer or slanderer of his Word, an adulterer, or be in malice, or envy, or in any other grievous crime, repent you of your sins, or else come not to that holy Table; lest, after the taking of that holy Sacrament, the devil enter into you, as he entered into Judas, and fill you full of all iniquities, and bring you to destruction both of body and soul.
And because it is requisite, that no man should come to the holy Communion, but with a full trust in God's mercy, and with a quiet conscience; therefore if there be any of you, who by this means cannot quiet his own conscience herein, but requireth further comfort or counsel, let him come to me, or to some other discreet and learned Minister of God's Word, and open his grief; that by the ministry of God's holy Word he may receive the benefit of absolution, together with ghostly counsel and advice, to the quieting of his conscience, and avoiding of all scruple and doubtfulness.
https://www.churchofengland.org/prayer-and-worship/worship-texts-and-resources/book-common-prayer/lords-supper-or-holy-communion