Nope, not quite and not according to ADOS. It's a bit hazy now (was 3 yrs ago) but the way the consultant explained it to me was:
ASD is a clinical condition and for someone to have it we look at a number of markers. For DS to get an ASD dx he has to hit all of the markers - so if you think of a graphic equaliser, we need all the dials to be over a specific line. Your DS is borderline for some of these markers, but nowhere near for others, so we can't diagnose ASD.
The caveat is that he still is borderline for some ASD traits, and ADOS isn't perfect. As he matures and as the world around him gets more socially complex, we could reassess when he's a teenager and find, actually, he is now hitting all the markers and has an ASD dx. Conversely, we don't know if he has a disorder or a delay - so he could catch up (three years on this is not looking likely to happen).
Now I know ASD is a life-long condition and I don't think the Consultant disagreed with that - she was more saying there are weaknesses in how we dx with such a young child, it is a clinical process so actually very black and white, it's not about the label it's about the help (Scotland doesn't have statements based on dx so that is true to an extent, but that was before the real truth of funding cuts started to bite).
All that said, we find that most ASD strategies work with him and we often use ASD as a shortcut if we're talking to strangers or people on the board or HCPs.
Sorry for such a long answer - the short answer is - no, but who knows, this time next year it maybe....