User blog comment:B214/Shin DxD 1 discussion/@comment-5.36.155.187-20180803173910/@comment-26709288-20180815043434

"……Super Devils. I heard from Sensei that there are three Devils who are called in such way in the past. Because they had abilities that are far beyond the other Devils. They are irregular existences which make people question whether they are even Devils. That’s what the Super Devils are. In the current world of Devils, Sirzechs-sama and Ajuka Beelzebub-sama still exist since they are still active."-Volume 16

So a Super Devil is merely a devil who has abilities beyond other devils. So a Super Devil doesn't require the baseline you put forth, it's merely a terminology to refer to a devil of devils, a devil with irregular power beyond other devils.

So if Michael, as a Archangel, has power beyond other angels, then he can in be referred to as a Super Devil.