The right question in my opinion is not whether or not this actor is an insurgent, it is whether or not YOU are a Counterinsurgent.
Current definitions and policy not withstanding; there are arguably three types of insurgency; Revolutionary that seeks to change the overall governance; Separatist that seeks to break away from the existing state/governance; and Resistance that seeks to defeat an imposed foreign presence/influence over the governance.
COIN is what the existing governance does to address these problems and their underlying conditions.
If you are not a member of the Afghan populace; but are a foreigner helping the Afghans to resolve its insurgency challenges, in US doctrine, you are conducting Foreign Internal Defense (FID). The biggest distiction being of course, not what is being down about what; but who is doing it. Always good to have a constant reminder of what your place is when inserting yourself into the middle of someone elses drama.
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