I guess that someone in your group has already suscribed. I would say yes. This is a rather surprising answer. Since you are supposed to answer not for yourself but for the whole group I would think that at least a few people are aware of these documents. The support of CRLs is needed for the cardholders.
Cardholders have then no means to know they talk to a non revoked merchant.
Anyway the gateway will know that a cardholder account is no more valid. The merchant will not know it directly. This is why my proposed 2 KP scheme is comparable in strength with your scheme because in both cases merchants get no assurance, before talking to the gateway, that they have a good non revoked cardholder in front of them. This strengthens my argument saying that my proposed 2 KP scheme is just equivalent. There is no overhead needed.