But the nature of heresy consists in withdrawal from the rule of the ecclesiastical Magisterium and this does not take place in the case mentioned [of someone who is resolved to believe all that the Church teaches but makes a mistake as to what her teaching consists in], since this is a simple error of fact concerning what the rule dictates. And therefore there is no scope for heresy, even materially."
If this accurately reflects the position of Billot, then this is an epic fail. One need not ACTIVELY WITHDRAW from the rule of faith, but the rule of faith can be passively missing or absent. Without this infallible and divine rule, supernatural faith is simply not possible. Cf. St. Thomas ... and even the Catholic Encyclopedia. It matters not whether the rule of faith has been actively rejected or whether it's simply absent and was never there in the first place. If you want to play semantics and limit the term "heresy" to those who have actively withdrawn from the rule, whatever, but the essential truth is that no one who lacks the rule of faith can have supernatural faith.
Formal heresy is not to be equated with active sin; what formal means in this context is that the formal motive of faith is missing. Billot wrote based on the false assumption that Protestants can indeed have the formal motive of faith that suffices for supernatural faith ... and then plays word games to make this fit.
Hypothetically, it is possible for someone to believe every single truth taught by the Church, but not believe it for the right reasons or with the proper formal motive. Such a one would be a formal heretic, but not a material heretic.
Conversely, it is possible for someone to not believe the vast majority (everything but the core articles) and still have supernatural faith.