Um, no, a DoMT can be created by any level 20 caster in theory (at the top of the SRD page it does say: "Even so, they are magic items that no longer can be created, at least by common mortal means." but I assume they aren't considering a level 20 caster to be a common mortal.

In theory you could be a bard, wizard, sorcerer etc. and still make a deck of many things. No Gods power required.