The date component never validates when it is marked as required, not even when it has today as a default value.
The reason seams to be that values are checked as $element['day']['#value'] while it should be $element['#value']['day'] etc.
Note that I included a diff file.

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#1 date.inc_.diff2.6 KBjpulles
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Title: date component never validates when required » Date component never validates when required
Status: Needs review » Postponed (maintainer needs more info)

I cannot confirm this problem. Could you check that it still exists in the latest CVS version? Date's have been getting an overhaul in #738678: Remove custom Webform "timezone" handling and #709854: Convert date component database storage to use ISO 8601 strings (similar to timestamps), so this may have been fixed in those issues, though in a different manner since the lines you changed in your patch have not been modified by those changes.

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Status: Postponed (maintainer needs more info) » Closed (fixed)

I've double checked this once again as part of #752414: Time fields with 12 hour format that are required are returning an error on form submission. Please reopen if you find the problem still exists, I cannot find it with the latest version.