As somebody who has 7 from 18/19 on my card and 10 from 19/20 from the 15 games that were played with fans, and then 2 for games which were behind closed doors, the use of 18/19 is annoying. A pro-rated 19/20 season may have seen me qualify, like many in this thread, and I don't think it would be fair to include any games that were not played with fans, so if 19/20 was to be used, a pro-rated amount should be the only fair way imo.
However, my bigger concern is the use of a ballot for all those not on 13, as this effectively becomes a closed shop. My luck with European final ballots is not great 0/3 for Basel, Kiev and Madrid, so I am not a massive fan of ballots, but understand the need for them for finals as I do think this is the only fair way for a final.
I am not sure introducing them for the league however, is fair. As it does pretty much become a closed shop with those on 13 staying on 13, as they will buy to maintain their credits and if you don't have any luck in the ballot you are stuffed pretty much. The late availability sales will be even more of a bun-fight than usual as well, as more people will probably not get one from the ballot. This is a dangerous route to go.
I hope they revaluate the ballot for 22/23 as I think that is the biggest concern from this announcement, as it does favour those who can only attend 1 or 2 each season over those who are just below the 13 cut-off.
I know the friends and family option has been added so you can attend games without buying it directly yourself. I do have mates who have season tickets so can get to most games, as I did attend 13/15 from 19/20, using my mates season ticket for the 3 I didn't have on my card.
The only silver-lining is, I will be able to get to all the cup games through the auto-cup scheme, just hope can do a fair amount of league games.