Not hard and fast no.
There is always some wiggle room.
A light car, with an unboosted/turboed/timed motor, basically running blinky, shouldn't have any issues. (10.5 to 13.5 might be a bit of a stretch though.)
If it's a heavy car/4wd, ruinning a lot of boost/turbo, even the stated limit might not be ok (i've blown an 8.5T rated ESC running an 8.5 in a DEX410.........)
I've also run an 8.5 in a 2wd on a 10.5 ( i think) rated cheapy ESC from hobbyking. That lasted a few months before an unrelated failure destroyed it. (bad soldering by the user......)
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