No. Chlorine dioxide as a disinfectant has the advantage that it directly reacts with the cell wall of micro-organisms. This reaction is not dependent on reaction time or concentration. In contrast to non-oxidizing disinfectants, chlorine dioxide kills micro-organisms even when they are inactive.
Therefore the chlorine dioxide concentration needed to effectively kill micro-organisms is lower than non-oxidising disinfectant concentrations. Micro-organisms cannot built up any resistance against chlorine dioxide.