Kinda. There are also the 32-bit bits on top, not (AFAIU) that different from their NT4 counterparts, such as the shell, COM/OLE2, TrueType, OpenGL, etc.; the core Win16 stuff (KERNEL/USER), which the Win32 layer thunks down to and which in turn invokes DOS routines; and the VxDs that intercept various pieces of DOS/BIOS and replace them with 32-bit code (“32-bit disk access”, “32-bit file access”, etc.). Only the first of those is new to Win95.