I wouldn't say so. EASA are recommending that operators introiduce an SOP where the critcal configuration change is done in a low workload environment. In otherwords, when the aircraft is stationary and the crew can concentrate.
Many aircraft already do this and I have had it included in my last three type's SOPs. Some Boeings have to have flaps selected to test the flying controls, as the outboard ailerons only operate with the flaps out and Airbus SOPs have the flaps selected as part of the after start scan.
Makes sense to me.