No, Apple says it will be available in "over 100 countries". And in the press release they specifically mention (U.S.), Canada, the E.U., Germany(EU) and Japan.
However, they haven't listed all countries. So I'm guessing this is probably every country in the EU plus a bunch of the biggest ones that usually get iOS features translated.
I'm sure the beta-testers could tell us exactly which countries. And if there are limitations outside the U.S., which is very likely the case.
Although I don't need it personally, this is incredibly exciting to me as it's is perhaps one of the most important and disruptive products(software updates) that Apple will ever put out.
Not only will it put a torch to the low tech and terrible prices of regular hearing aids, it will also let those with very little hearing loss get access to affordable hearing aids, buyers who don't need them to an extent where buying regular hearing aids makes sense.
And those who are ashamed of looking old, sick, or impaired with traditional hearing aids are now just "listening" to AirPods Pro, just like anyone else would.
This is huge.