If your basis for thinking she isn’t trans is the fact that she hasn’t had treatments, then yes, she sounds trans to me.
Obviously I don’t know her. As far as I know, the only requirement for being trans is feeling like one’s body doesn’t match one’s mind. Medical changes are not a requirement.
I s’pose that’s the crux of this whole conversation, isn’t it?
Edit to add: I wonder how she feels about being called a cisgender man, after she told you she’s trans. I hope nobody is pressuring her.