So it's not as simple as "Just write a .service with ExecStart=/etc/init.d/whatever start", but it's also not too complicated, especially if someone forks the sysv generator and keeps it working like I said in another comment.
The pain point was never "generating a textual representation appropriate to the init system"; the problem was always the underlying startup and teardown of the service itself.
From my experience yes, even the legacy stuff is easy enough to convert.