Not true. With OS-level gestures the driver simply reports the position of each finger to the OS, and the OS handles the "meaning" of the various gestures. With driver-level gestures the driver interprets the meaning and passes "events" to the OS (like scroll up, scroll down, forward, back, etc.).
With OS-level support you get the same support across all multitouch devices, which allows for cheaper device development. For driver-level each manufacturer has to do gesture detection--this gives the option to provide better detection (due to tight integration with the hardware) but it also means that the manufacturer could cheap out on the drivers.
From what I understand, Ubuntu does OS-level gestures. Win7 apparently has some OS-level support, but still seems to have some aspects of driver-level with customization in the device drivers.
It still sounds like a driver implementation except its extended to allow OS-wide operations to perform those fancy moves on lion desktop.
If you look into your /System/Library/Extensions folder you'll find this: AppleMultitouchDriver.kext
Guess multitouch gestures still need to go through a driver after all.
Even if mac would support every trackpad out there, it would only mean mac's (or any other OS for that matter) got a generic driver to detect the device, read the gesture input, and then perform the command by analyzing the gesture input. Just like plugging in mice, which we are now so used to by now. Just because you can plug n play, it doesn't mean there is no driver to get the device working. You can probably argue that those built-in drivers are integral parts of the OS. Then in that sense, yes it is "OS-level". However, it doesn't eliminate the nature of how a driver would work.
I am not a hardware/driver developer. so prove me wrong if you will.