

No.
By itself, apt will give you headaches.
Debian migrated to new paths for security non-free firmware in repositories from 11 to 12, and apt goes to v3 in 12 to 13, which changes the format of sources. There is a new apt modernize-sources command, but it assumes your paths are correct.
If you know what you’re doing, you can do this by correcting the repo paths and do the without-new-packages upgrade, but be prepared to fix apt.
If you’re a casual user, maybe stick with 11>12>13.
Honestly, there were so many fundamental changes in the 13 upgrade for certain packages that I had to fix on a couple of machines that I’d be hesitant to try no-scoping the 11 > 13 upgrade.
I flew by the seat of my pants and managed to pull off 10 directly to 12, but I wouldn’t do it for this one.