Many people feel that way, but it had multitasking, its own APIs, its own memory management, and so on. Disk access was still handled by MS-DOS, but that was it. I’d say that it’s an OS as it is far more than a shell, but we can also use Microsoft’s terminology from the time, “operating environment.”
Not sure if it's important, but Windows 2 is still fundamentally a graphical shell on top of DOS. I think the Unix parallel would be: is the X Window System an OS?
macOS and Next Step rely on BSD and the Mach kernel. Android relies on Linux and the dalvik jvm.
Is Windows 95 an operating system ? If not why not. After all it relied on MS-DOS also.