I don't think it was necessarily intended to be one -- and the presence of Desmond Llewellyn as Q argues against it being one -- but I think you can choose to regard it as one if you like, and the film doesn't give you definite indicators that it isn't.
From an age standpoint, Brosnan's Bond is certainly too young to have been working for MI6 in 1962 when Dr. No came out (and so was Dalton's for that matter). Then again, Bond is kind of like Batman in DC Comics -- eternally about age 35, ever since he was introduced 85 years ago in 1939, and you just ignore that fact and suspend disbelief in order to keep enjoying the stories. You're not really meant to overthink it and start quibbling about timelines and specific years and ages and so on.
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