A topic from AEG's L5R CCG Rules forum, copied for Oracle of the Void from a copy of the forum saved in October 2015, so pages it didn't save are missing. Players' names are left out; the rules officials are named. Rulings are as they stood on these dates; later rulings, the rulebooks and the Rules Archive may differ.
A player, 23 May 2011
One Action, Two Strikes 0 GC
Battle: If the enemy leader has taken any battle action during this battle: You may take two additional battle actions after this one. You will not take any other additional battle action this battle.
Question: Does my opponent passing count as taking a battle action for One Action, Two Strikes?
Zen Faulkes (rules official), 23 May 2011
Does my opponent passing count as taking a battle action for One Action, Two Strikes?
A Battle action begins with the designator, "Battle" (http://rules.l5r.com/CE_Card_features#Abilities). I don't believe you'll find "Battle: Pass" anywhere. Unless or until you do, no.