Yes. The Givi USA website is incorrect, grouping the 2019 accessories with the 2016-2018 bikes. I ran into the same issue with the SW-Motech hardware (both the rear carrier mount, and the side case mounts). As you noticed, the distance between the footpegs and the under tail bracket is different. If you look at the Italian version of the Givi website, they list a different rear rack mount number for the 2019 model (1176fz vs 1152fz), so it appears they're working on an updated version, for the new models.
Givi needs to update their USA website, to match what they've got listed, for Europe.