Literally every UN update on death count explicitly says the numbers they are providing are only confirmed deaths, and they expect the actual number to be much higher. They aren't even counting the major cities that have basically been destroyed over the past 2 months.
It was the same in Iraq, so his comparison is still valid
No, it's not. He's comparing the final official numbers from Iraq 20 years ago to the current confirmed number in Ukraine today. The number he's using for Ukraine don't even include an estimate for places like Mariupol where we know there a tons dead because they haven't gone in and counted the bodies yet.