It would still require install scripts to get from a fresh Arch install to Omarchy. And then those scripts would also be adding scripts that aren't really necessary for any single person's dotfiles but that’s not really the point.
The difference is there is an implicit contract. Omarchy is maintained as a complete system. You can install it from an ISO, update it like a distribution, and expect someone to care about whether the pieces work together. hyprland is a minimal compositor and you have to figure out how to put together the other pieces of a shell to get a complete experience. If you're doing that piecemeal, you have to maintain and update those on your own. Changes to each piece that break something has to be addressed individually. With Omarchy, that is maintained by someone else and the downstream user just runs an update to omarchy. It compiles a group of disparate packages and makes something cohesive enough to not require jumping into configuration files to use.
That is different from downloading someone’s dotfiles. A dotfiles repo is usually written for one person’s machine and workflow. Omarchy may have started from DHH's dots, but it is structured as something other people are meant to install, update, override, and live in. It separates Omarchy’s defaults from user overrides [1].
I'm not sure what exactly is required for something to be considered a 'distro' but omarchy definitely feels more like one than not, albeit a relatively thin distro based on Arch.
[1] https://learn.omacom.io/2/the-omarchy-manual/65/dotfiles