Almost. There are a few you can't get with:
Greta, aka Granny, Mia's grandmother. IMO unlikely.
Makith, the goblin shaman. IMO unlikely.
Siv, the 4th giantess at their camp. Possible addition later.
Daiyu, proprietor of the Black Dragon shop in Greyport. The dev wants to upgrade her to one of the girls.
The Miller's wife (unnamed); you only meet her briefly, if you manage to burn down their house. IMO unlikely.
Greta, Makith, Siv, and the Miller's wife all have small-but-vocal fanbases advocating for them to be added.
Additional girls we haven't been met yet who might be added:
Cath, who supported Roderick's attempt to take over Weirdwood. Almost guaranteed.
A dwarf girl blacksmith. Almost guaranteed.
The Baron's Wife and/or Daughter. Likely. Though the daughter might be Cath...
Whatever hatches from ED's egg. Almost guaranteed. Though I'd ROFLMAO if it's a boy...
A cave goblin girl. Possible.
An orc girl. Likely.
A couple of anthro girls for the unused cells in the Tower, comparable to the Bat Breeder. Highly likely given they were on the dev's most recent poll of higher-tier supporters about what to work on next.
Victoria's niece, as a nanny for her aunt's kids. Possible.
...and probably some others I'm not recalling.
Note that the Book of Girls is running out of space. Daiyu plus the 'almost guaranteed' girls would only leave 2-3 spots for others, and the dev has said he doesn't want to add more pages to it. So a lot of these wouldn't be added. (Though with a small revision to the BoG, returning it to its original layout, there'd be room for several more girls.)
Personally I'm A-OK with the MC being unable to get with some women. Even with his nigh-supernatural (possibly actually supernatural) ability to bed women he sets his sights on.