Not for much longer, perhaps not even now. There's plenty of data avaliable to anyone, and people are finding ways to use that data more effectively.
Mid-term, I believe the only real moat is going to be human labor - that is, RLHF and other funny acronyms that boil down to getting people to chat with the model and rate how they feel about its answers.
Software improvements (architecture, training process, inference) are always one public paper or leak away from being available for free to anyone. Hardware improvements will spread too, because NVIDIA et al. would prefer to sell more chips than less chips. Meanwhile, human labor is notoriously expensive, only getting more expensive as economic conditions of people improve, and most importantly, whatever "spark" of human intelligence/consciousness there is, this is where it cannot be automated away - not until we get to human-level AGI.
Human labor is the one thing that you can only scale by throwing more money at it - which is why modern businesses seek to remove it from the equation as much as possible. Hell, the whole pursuit of AGI is in big part motivated by hope of eliminating labor costs entirely. Except, in this one pursuit, until AGI is reached, labor is a critical resource that has no substitute.
That's my mid-term prediction. Long-term, we'll hit AGI and moats won't matter anymore.