Not at all. I'll tell you why right now:
Flash outdamages Batman
Flash outfootsies Batman
Flash's d2 anti-airs Batman j2 99% of the time
Flash has better mixups then Batman
Flash has better oki then Batman
Flash punishes Batman's slide ON HIT
Flash can shake through all of Batman's zoning and isn't even forced to get in if he doesn't want to
If the Flash player doesn't have the defense of Wound Cowboy and can actually block all of Batman's mixups and react to f3 and trait cancel gimmicks, the matchup is extremely hard for Batman. If the Flash player gets the first hit of the match, and has a 60% life lead on Batman (meaning Batman has 40% of his white bar and Flash has 100% of his white bar still) what is stopping the Flash player from sitting across the stage shaking through all Batman's zoning until time runs out and he wins?
Think about it. If Flash has the life lead and has good defense, he can anti air ALL of Batman's j2's with his d2, block all of Batman's mixups on reaction, and shake through all of Batman's batarangs. How is Batman supposed to make that comeback? It's virtually impossible. Flash can just sit there and block and d2 and shake until the time runs out. Not to mention he outfootsies Batman and if he lands a mixups while playing defensive he takes another 60% out again from Batman
You forgot to mention that Flash's dash ins go right under bats and that his jump one beats all of batmans jump normals. I play this matchup a lot with Snke and I generally loose to him 3-2 in tournament. The fucked up thing about flash in that matchup is that you can have a 80% lifelead and still fail to lame him out. Snke has impeccable defense and I have to work my ass off just to open him up once, and even then Ive usually used all of my resources at that point. On the flip side, flash jumps in with jump 1 (which is very hard to anti-air with bats), if he does 2,1 it jails, he can go low, overhead, or wait and mb torpedo to punish my backdash. He has the touch of death, converting any touch into %50+ (there goes that lifelead) carrying you fully into the corner, where he rapes you with a 10 way guessing game. Snke never punishes my slide on hit though, you know why? Becuase he always stuffs it with d1d2 lol. No discredit to Snke, hes nothing short of an amazing player, but i feel batman has to work much harder in this matchup then flash. Much, much harder. I used to think this was 5-5, but now im leaning towards 4-6.
So sick of people saying batman is hella good "because trait bats bro.." -_____- Batman is an extremely honest character. He has nothing that is extremely dirty. His trait is amazing, but there are answers to it (like pushblock, d2, or idk, maybe just fucking blocking lol) unlike BS traits like sinestro, am, mmh, etc. He has a vortex that requires meter but most importantly requires you to first OPEN UP YOUR OPPONENT FIRST to use it. Batman has to beat you by getting in your head, beating you in footsies (which is where trait bats become so good), by capitalizing on your mistakes, and in some matchups zoning. Thats about as honest a character as I can think of. Batman is NOT top 10. He is just barely outside of top 10. Most likely #11 or maybe #12.