1.40.2.29 wrote: There is a completely different model of K-9 Mark I due to star in the upcoming movie, Timequake and the comic K-9 is identical to that model. It is clearly intended to be another regeneration. Just look up K-9 Timequake. And then compare that image of K-9 to the K-9 Mark 2 from the 2010 series. That is what you call regeneration.
But we don't know that. We can't say 'it was a regeneration' without in-universe evidence, all we can say it "he looks different."