I don't think it is. When you're setting up your phone, you have to go through the "hey Siri" training to enable it.
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This is not true. It has been on by default since iOS 9.
I've got a phone here on iOS 12 that started from a a clean wipe this morning. The initial setup asks you if you'd like to enable siri (and certainly pushes you in that direction), but if you don't accept, neither hey siri nor holding down the power button will activate it.
Yeah I can confirm. I just set up my iPhone and it absolutely asks if you want Siri activated. I said no, and it doesn’t respond to any of the keywords or button presses and is completely disabled throughout the phone.