I mean, it will, just because Fujino will make it "feel like it", kinda like how Sinon despite not even knowing Kirito in this AU is supposed to count as NTR too and how Suguha's arc was completely warped somehow to conveniently not happen just to actually give Hebishima a chance to "NTR" her, Fujino made this OC Alice "befriend" Kirito and clearly show some 'harmless spark' between them so when she inevitably gets fucked by another man it's meant to "feel like NTR", that's the whole point of all the non-Asuna girls in this game also ending up fucking by another man, none of then SHOULD count as NTR but this world is specifically twisting them and their circumstances so for the player it feels like it (Like almost all SAO "NTR" doujins that include the non-Asuna girls do really XP).
Oh yeah, that's why I said it was a 50/50 (His character literally gets introduced having been dumped because he was watching a NTR video of the dude NTR-ing Sakura in Fujino's other game, after all, if he wasn't a side-character that would usually be a massive red flag for his luck), as I said it all depended on how Fujino wanted to build Alice's story, like, the fact they were investigating a sex trafficking ring basically screamed how very easily she could end up with a 'bad ending'. And hey, there is even a small chance that even if Fujino still gets rid of Hebishima he stubbornly decides to keep the Alice storyline intact :3