It could be, but they are using Gen 9 Intel chips, if they were to update I presume bringing the latest chips would be the most sound
Almost certainly not. Apple uses its year designations sparingly. They haven’t indicated a new graphics option warrants a new year moniker for the 16” anywhere else or ever before for other Macs as far as I’m aware!
Sure, but there are no hard rules to when Apple considers a model to be new.
They've certainly done a minor spec-bumps within an Intel chip generation and called it a new model, as a few examples:
- Mid 2018 and Mid 2019 MBPs both used 8th Gen Intel chips.
- Mid 2013 and Early 2014 MBAs both used 4th Gen Intel chips.
- Early 2015 and Mid 2017 MBAs both used 5th Gen Intel chips.