I don't think it's much of a footgun, and I don't think it's limited to CPython.
In Python 3.6, kwargs are ordered. In all versions of Python, kwargs are a dict. Therefore, in any implementation of Python 3.6, dicts are ordered.
The dev team has stopped short of promising that dicts are ordered, but I can't see how one would realistically be harmed by assuming it to be true.