I think yes, it's like declaring every single argument as const.
STRUCT (INT x, y) z = (1, 2)
Here z is a const struct. If you wanted a variable, you'd have to say STRUCT (INT x, y) z;
z := (1, 2)
or equivalently REF STRUCT (INT x, y) z = LOC STRUCT (INT x, y) := (1, 2)
Basically a variable has a REF mode.