Shims in the kernel seem a bit anti-social, since all module developers are expected to contribute to the shared core code. Of course it can be done, and it has been done. But I think FUSE is better if all you care about is portability, and you don't mind the heavy performance cost. My module could be ported for FUSE of course, but it's a lot more work than it may seem, the kernel interfaces are too alien compared to a userland library.