Exactly! I wrote about reframing it as "Software" debt: https://www.evalapply.org/posts/software-debt/index.html#mai...

A software company is a software company, not a technical company.

So, in terms of Risk and Responsibility, discussions of Technical Debt don't sufficiently examine the nature of Risk (across-org complexity sources, wetware, workflows, market feedback cycles etc.). The concept also skews and pigeonholes the Responsibility of dealing with it to a small subset of people.