Sure, it's just another application technically. On more practical level, it's pretty much an OS.
But it's really a gradient. As more and more services and systems move from being systemd services (or whatever) to in kubernetes, I see it as the position along a gradient shifting. Both are operating systems. They're different operating systems, doing different things, but both manage and provide resources for user payloads, both run apps, both host a user interface (apiserver for kubernetes), both have state (also apiserver, vs file-systems).