The entropy depends on how the password is generated. If I choose ten words from my own dictionary then the entropy depends on the size of the dictionary. But if I re-rolled 15 times until I got words that I liked then one would have to decrease the entropy accordingly. But someone else couldn’t distinguish those two cases if they knew nothing about me (modulo common human psychology).
The point is that entropy depends on how the agent generated the password and has nothing to do with character sets or length in itself. So sure, this could be said to be a certain approach to approximating entropy in the general case, but I see no reason to put adjectives in front of “entropy-based password validation” which somehow suggest that it’s the number one, objective way to do it.