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This should be correct. For any cell that isn't green after your first guess, there's only one other possibility for its value.

It's not guaranteed you will always win in 2 steps because occasionally you will win in 1 step.

Isn't 1 within the bounds of 2?

There's a difference between "in 2 steps" and "within 2 steps".

Splitting hairs seems like grammar policing. I can even see action 1 and null action if I squint hard enough.

Yes. Yellow and grey mean exactly the same thing in this game: Flip it.

Hoping that you are being sarcastic...