Does changing the recipient count as a transaction

Hello,

I have someone asking if changing the recipient for a file that has already been sent out count as a transaction. I know that the original file sent out obviously counts, but if they need to change who a signer is, does that also count as a new transaction? I can find tons of information on HOW to change a recipient but nothing telling me if it counts as a transaction, which is our main concern. 

Thanks