Sure looks that way.
Minus the odd picture, Kotaku reports that come Janurary 2009, PS3 games will be required to have trophies. This seems to fall in line with what they said they were going to do with trophies by eventually making them required while at first developers could patch them in.
Kotaku: (be warned that the picture posted in the link is a little odd)
"That's right. MANDATORY. Refuse to put trophies in your game and you, developers, will be SHOT. Your families, BILLED for the expense. Or...at least, Sony will be very cranky with you. Because, come January, all PS3 games will have compulsory trophy support. At least, all the new ones coming out after January. So no more patching, no more developer ambivalence, no more inconsistencies. Not sure why Sony didn't do this from the start, but doing it now, at the middle, is better than never doing it at all."
