No, as far as I know. CSEQ is not required to start at zero - it may start with any value. See RFC 3261:
8.1.1.5 CSeq
The CSeq header field serves as a way to identify and order
transactions. It consists of a sequence number and a method. The
method MUST match that of the request. For non-REGISTER requests
outside of a dialog, the sequence number value is arbitrary. The
sequence number value MUST be expressible as a 32-bit unsigned
integer and MUST be less than 2**31. As long as it follows the above
guidelines, a client may use any mechanism it would like to select
CSeq header field values.