Isn't that just a scale issue that exists with or without subnormals? If a and b are closer to zero than the smallest representable number, a and b compare as the same. With subnormals your smallest possible number is smaller than without, but it's still the same issue.
Because subnormals are fixed point, ie. have a fixed exponent, the difference of any two distinct subnormal values is nonzero like with integers.