So should we instead move to a netdevsim PHY model where we would emulate an mdio bus and use a pure genphy driver instead ?
I think what you have is a good start. It actually requires somebody who is interesting in testing to take it further. And i doubt a pure genphy driver is sufficient, i guess it will need a driver specific for simulation. There is some things you can test via the PHY driver API, and other stuff you need to emulate registers. So it will end up with a hybrid of both.
Andrew