Not historically, but the last few years have been extraordinary. Covid caused problems, in terms of a lack of new referees, a lack of promotions, and a significant number of referees deciding not to return after the lock downs. That caused problems at L4 and L3 as there just weren't enough referees at those levels to cover games, and to an extent the FA have been playing catch up since.
This year sees the first season of the new promotion pathway, with the previous system having been in place for decades. There were some tweaks along the way, like moving from marks out of 100 to the revised well below standard through well above standard, and aligning the promotion season to the playing season. but the overall principle was you spent a full season at a level (unless your CFA allowed 7 to 5). Now there is no overall mark / grade, and referees could in theory be promoted twice in the space of 6 months.
My experience of change, not just in football and refereeing, is that when you introduce that level of change in such a short period of time there will inevitably have to be changes over the following years.
