Technically no, thermal is x-rays -- even at 1MeV+. X-rays are produced by electron interaction, gamma by nuclear reaction.
So the ~10keV emission from tritium is gamma, even though it's eminently within the realm of electrically produced x-rays.
Well, I suppose it might be worth arguing that x-rays from a hot proton, neutron, and other nucleons, plasma (or all the way up to quark-gluon plasma even) might be gammas, but anyway, such cases are clearly where the distinction lacks value.
As for black body, it may get complicated at extreme temperatures, where pair production (>1MeV) enables additional degrees of freedom. You still have the same old Planck distribution among photons -- there are just have additional forms of radiation as well.
I think the consequence of this is, not so much the spectrum changing, as the heat capacity of space itself going up -- in addition to EM modes, electron and etc. modes become available. Again using the equipartition theorem, when all these modes are in thermal equilibrium, each has a distribution given by its statistics (an electron-positron gas will have a Maxwell-Boltzmann distribution, I think?).
Tim