I'm not sure I get why the comparison to the Kernel is needed. GPUs are wildly complex. Rendering is wildly complex. Managing memory and data is complex. Managing connected hardware is complex. I am not sure why anyone would expect a GPU Driver to be small while also doing a billion things and playing games as well as mature gaming platforms.
Most of the GPU software stack can reasonably be outside the kernel. There's no obvious reason why much of it would need to be in ring-0 where bugs cause OS crashes and security vulnerabilities.
> Meanwhile the open-source NVIDIA "Nouveau" driver is around 201k (21.7k blank lines, 24.3k lines of comments, and 155k lines of code). Or the Intel i915 DRM kernel graphics driver is around 381k lines via the same cloc judgment.
But without separate line counts of the generated data tables and actual human written code, we don't have the real line count numbers to compare.