Dunno yet. Ultimate isn't available in kick off and I've just been playing UCL ties.
But playing as Man City I just got beat by Spurs 6-1. So... yeah, it's definitely harder so far this year. And considering CM is usually more difficult than kickoff matches, and I've yet to play on Ultimate...
There's quite a lot to still get used to but early on it feels like the challenge is there this year. Is the balance too far on the side of the CPU being cheaty? I haven't felt that but we'll see as time goes by but the only issue I have at the moment is the CPU's first time shots. (And as others previously mentioned, some of the first touch passing moves by the CPU aren't great but they aren't as prevalent as in the past and often can be defended.)
Also, loads of people are complaining about the CPU difficulty in squad battles - there being way too much bullshit - so look out for EA making changes because of that. We'll see.