I would say they are - but had to send mine back, too stiff over toes when trying them on. Length and width they were perfect tts for me so I didn't think going 0,5 up would solve this.
Just try them, if u don't feel stiff material over big toes with every step I think they can be comfortable as boots can be.
Collar is nice and soft. Also no problems with lacing up high, it holds good.