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I don't think so. Watch this video
Pause at the very begining. Instead of just three game mode options, its four and the fourth one is critical. So it is available at the begining of the game.
EDIT: I don't see the video. Here's a link: YouTube - Kingdom Hearts Birth by Sleep: Gameplay Gamescon 2010
Yeah I'm starting on Critical Mode. Started on Proud Mode with the Japanese version so it's time for some extra challenge.
And I'm pretty sure that the whole "Critical Mode is locked" thing is just a rumor. In KH2FM, Critical Mode was unlocked from the get-go so there'd be no reason to change it.
I'm really looking forward to critical mode. Do you mind if ask how the Proud mode of BBS compares to KH 1?