Not really, everyone is still only allowed 3 commanders, and there are more than enough viable free commanders to deal w/ the paid commanders. While it might give a slight edge, I never feel like it more than made up for the mistakes that I may have made in teching, micro, tactical decision making etc...People just always want something to blame their losses on, and p2w has a nice label that everyone accepts as being unfair. All your really doing is hindering yourself from improving. If your shortcomings are always the fault of the game design how do you ever expect to learn and improve? Sorry but unless you are in the top 5% of players...you could have always played better to win, and even the top 5% still acknowledge when/what they could have done to win. I'm really tired of all the faction imbalance QQ'ing.
Having a good K/D with a ACW-R in BF3 was not pay to win. It was a pretty good gun but only slightly out performed most others and even then it was still inferior to a few stock guns such as the M16A3. Having the alternative to use a ACW-R doesn't mean very much in a game about shooting people. However having the option to use more units/abilities/tactics in a STRATEGY game is pretty unfair. That would be the equivalent of something like sprint ability or knife attacks in BF3 being locked behind a expansion pack, that would be pay-to-win.
Even if they were all perfectly balanced (which will never happen btw) it is not fair if you paid to have more available choices than your opponent in a game genre that is based around making decisions. Even if by some miracle they do manage to eventually get the balance spot on in the end, they already have I wouldn't be surprised if they continue to release doctrines that aren't remotely balanced for weeks or even months in the case of the Tiger Ace. You might say "well its going to be fixed eventually" but I say look at the large volume of people that have uninstalled because of it and even some of the people that are still playing today either stopped playing for a while or had a terrible experience for months because of this business model.
Just because both players only get 3 doesn't make it fair either. You might have the same number of possible doctrine choices per game, but there are a ton of variables that will give the advantage to the guy rocking the DLC commanders. He has the potential for a stronger combination of 3, he has a wider variety of niche role units that can be fielded, and its also pretty likely that several players out there excel using one strategy repeatedly but are not very well rounded players. For example look at Vesat and CrazyTiger in CoH1. Every single game they spammed Volks with blitz nades and then Pumas. When they tried other playstyles they were only average players, but they were fairly successful doing the same thing over and over again. Now just imagine people like that in CoH2, that aren't very well rounded players, but they do excel at using one cookie cutter strat repeatedly. Except now there is a chance that the cookie cutter strat is only possible through paid DLC. How is that not pay-to-win? If you win a higher amount of games because you paid, its p2w.