Imo, they should have kept the top tier versions of the penances as they were, and simply added more stages in between, instead of lowering the requirements of the top tier versions by up to 2/3.
Now that they have taken this route, i think they should reintroduce high tier penances, potentially in a separate “Heroism” section. Penances that do not award penance points, but are very difficult or very time consuming to complete, and award cosmetics with special effects.
I have suggested the same thing a while ago, so i will simply refer to an older post:
They could even add multiple additional stages, where the first stage adds a glow inside the cosmetic (as i masterfully created above), and the second stage adds an additional glow (or other effect) around the cosmetic.
For example:
Penance (top tier): 500k kills → skulls portrait frame (as it is currently in the game)