Why would it be dubious? Whether you disliked the lack of development/exploration of Matilda's character, it doesn't change the fact that she was still a named woman who had a conversation with another named woman (her mother, Frey).
There's nothing dubious about this. The film passes all three tests.
Alice Braga's daughter is in the movie but only as a plot device that is never characterized and is never given anything interesting to say or do. She only has token interactions with her own mother, and spends most of the third act
unconscious.
Jodie Foster is certainly the most powerful figure in the narrative, but she's also the villain.
So dubious pass, although not especially progressive or offensive when it comes to gender politics.