That's almost what WINE does which is, apparently, not an emulator. Small reimplementation of Windows userspace and translates DirectX to Vulkan/OpenGL. So if I do x86 -> ARM binary translation AOT and run that with WINE, is it an emulator?
According to WINE itself, WINE is an emulator.
Ultimately there's a spectrum between emulation and native code and where you draw the line is an arbitrary and subjective choice.