Yes they would if one is wanting a short barreled rifle with stock. Pistols can have any length of barrel without them being a SBR.I guess a person needs to apply for permission to acquire a 9mm carbine with a barrel in the 9-12" range mentioned above.
Or you can do like I did. I pinned and welded an extended flash hider onto my 10.5" 9mm barrel to get the OAL to 16".