Not really. Most of the earlier movie Batman villains were rather over the top villains that may have an axe to grind but were depicted as more outright evil.

The Riddler in the The Batman honestly comes across as more of a hero in the first two acts of The Batman based on who he is targeting. All of the Riddler’s victims are causing massive harm to Gotham and the city’s political system seems unable to really address it. This includes Bruce Wayne’s complicity in the corruption of the city by being a derilect chair of the charity that is supposed to be improving the city.

If you end the movie when Batman and the Riddler are in the jail cell, you would be hard pressed to identify the Riddler as a villain; he is just a kind of vigilante that Batman is. It isn’t until the Riddler attacks Gotham as a whole when the Riddler actually becomes a villain.