batting or not---if it's going to be laundered- you would probably want to do some quilting on it---otherwise when it is washed & dried it will (puff) in some spots. twist...not lay flat--some at least a minimum amount- like an X across it will keep it (together) when it is laundered-
even a 12" square cotton top, fleece back- will come out wonky if it has no quilting keeping the layers together.