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Don't think so. U1 LED is driven with wrong polarity and has negative transistor supply.Please find attached again the LTspice file. I hope now is ok.
Many previously mentioned problems are still present, ignoring balanced ground fault, huge circuit power dissipation, about kV voltage drop at current limiting transistors.
Please check particularly sub clauses 4.1 General requirements and 4.2 Types of IMDs.I have to be in compliance with the IEC 61557-8. But I will ask to the standards department to be sure.