I'd have to say it's a no. In fact, I would probably rank it lower.
This. If it had been like kh1 it minds well have been kh1.
Though it was hard to grasp, after I done so, I found the card system rather innovative and honestly by far the most strategic of the series. (as well as balanced)
Many hate the system because they had trouble with it but, from what I can tell, it's also cause many just dont take the time to explore it fully and come to truly appreciate it. (or to fully understand it enough to still dislike it)
As Solosis pointed out there is no blindly running in and bashing X till the enemy is dead. You have to watch what you do, conserve attacks, plan out your deck so that it works, etc.
It felt more rpg than any of the KH games to date even though they are all listed as action-rpg.
Story wise well yes I did enjoy it, it was rather good for Sora's character. He actually felt like he grew, he actually got angry and even a bit antagonistic at times.
And because of this you can see why I would be rather
pissed angry at how it ended. Everything to his character was lost because of memory erasure only for me to get a shounen/stupid Sora in kh2 after he woke up.
it just felt like a set back to dumb him down as kh2's writing seemed to do after seeing the side of him I got in CoM.
Riku on the other hand, I rather enjoyed his story in the game. It was nothing really grant or such but it was awesome to play someone other than Sora for the first time and I liked watching he come to terms, at least partially, with darkness.
Riku's story also contributed to the larger mystery of Diz, the org, etc.