Yes, it is. A recall is about the fact that there are unsafe devices, not about how they get fixed.
> A recall is issued when a manufacturer or NHTSA determines that a vehicle, equipment, car seat, or tire creates an unreasonable safety risk or fails to meet minimum safety standards
Yeah, technically it is called a recall because of NHTSA's terminology. But it's not a recall in traditional sense. It's an OTA, where customer's cars don't have to be physically recalled.
> A recall is issued when a manufacturer or NHTSA determines that a vehicle, equipment, car seat, or tire creates an unreasonable safety risk or fails to meet minimum safety standards