Counts as double insulated, i.e. reinforced.
To what voltage, is the question...
Suspect it may be adequate by the letter of the law, but I agree with others that a layer of tape or film would be more comfortable.
If applying a sticker or tape is a PITA, you might consider getting the board with extra soldermask or silkscreen layer(s), or with conformal coating applied through a stencil. Or the parts could be similarly pre-treated (probably the bigger pain though?), or customized from the manufacturer if quantities permit.

Anecdote: once had a series inductor jumpered out on an inverter board. This was a large chip style inductor, with ground poured around it. I did the mods on our existing prototypes by bending some wire into jumpers and spanning between the pads; the protos we got from the assembler, they just took some bits of 0.025" square pin header and slapped those down. So, my version had height over the ground pour between pads, theirs was flush over the pads and pour. Several of the assembler's boards did indeed work at up to 650VDC; one did however fail shorted, in that location.
On a related note, another proto we played with (earlier on that job), a 4-layer ExpressPCB board, where the inner layers didn't have any special clearance assigned, just the usual 7 mils. Similar failure rate, one shorted out, a few others worked fine.
Tim