No, it is not a strict subset. It is not even a subset.
Here is a demonstration, on a desktop PC running a major GNU/Linux distribution without any customisations that should affect the result, that there is at least one datum present in sysfs that is not present in procfs:
$ grep -ir `cat /sys/block/sda/device/model | cut -f1 -d' '` /sys 2>/dev/null
/sys/devices/pci0000:00/0000:00:1f.2/ata3/host2/target2:0:0/2:0:0:0/model:SanDisk [...]
Binary file /sys/devices/pci0000:00/0000:00:1f.2/ata3/host2/target2:0:0/2:0:0:0/vpd_pg83 matches
$ grep -ir `cat /sys/block/sda/device/model | cut -f1 -d' '` /proc 2>/dev/null
Binary file /proc/26887/task/26887/cmdline matches
Binary file /proc/26887/cmdline matches
This also demonstrates, incidentally, that on that PC at least, the set of all data exposed by procfs is not a subset of the data exposed by sysfs.