The ex-England international formed part of the Gunners squad that made history while sweeping to the Premier League title in 2003-04.
Arsene Wenger’s side went an entire campaign without coming unstuck, with their unbeaten run eventually stretching to 49 games.
Pep Guardiola is hoping to emulate that achievement this season, having negotiated 13 Premier League games unscathed so far, but Cole doubts they will match Arsenal’s heroic effort.
He told ESPN FC: “I'm not sure about the similarities.
“But so far they have the zero for losses, so you can compare on that front. They've clicked and connected.
“But it's tough to go 38 games unbeaten. Can they do it? Who knows but it's looking good for them so far.”
Pressed on who would win if Arsenal past met City present, Cole added: “I think the 'Invincibles' would win. No bias.”
While casting doubt over City’s ability to go an entire season unbeaten in the league, Cole has also questioned whether Guardiola’s side will get their hands on the crown at all.
“The title race is not over," said the 36-year-old full-back, who is now on the books of the LA Galaxy.
“Man City are on fire, playing well and seem to have come together. But as players you never give up.
“So with Chelsea the current holders of the cup [title], I don't think they will give it up too easy. Hopefully they can retain this beautiful trophy.”
The former Chelsea man added on the hopes of Antonio Conte’s side in 2017-18: “As players you never make one trophy a priority.
“They still have a chance to regain the league, so that'll be in the back of the mind of course, to make history and win the Champions League again.
“On all fronts, Chelsea are fighting for a lot of trophies.”