The answer is yes, but that doesn't mean that it has to be behind what's causing your problems. The level of 48 for T2 diagnosis was picked because retinopathy is rare (therefore not unknown) at BG levels beneath that. It's kind of a backstop, to my mind.
I had an interesting set of diabetic symptoms long before my BGs went over 48 - the symptoms largely went when BG came back into normal range. Lesson for me is that my problems start at BG levels around 43 or 44. I know people who had higher BGs with no symptoms, so there is no guaranteed read-across from one person to another.