You have the right idea but the wrong specifics. The boundary you're alluding to isn't the kernel/userspace boundary, it's the `libc` boundary, which is admittedly privileged by convention if not by Ring 0.
On most Linux systems this is regrettably `glibc` (in a container where you get to choose everyone chooses the superior option of `musl`), on all Darwin systems this is `libstandard`.
This thread is more concerned with Linux, so you are probably dealing with `/lib64/ld-linux-x86-64.so.2`, which operates in userspace but is by convention and opacity quite clearly part of "the system".
The kernel modification is a much bigger, much weirder side effect of a weird Nix loyalty test around shebang lines in shell scripts, on which is has opted to be intentionally and violently incompatible with everything for no benefit other than incompatibility.