Yes, I am sure.
Annex VII only rules out connecting to the PSAP/112 side, not routine network attaches. To detect faults in the “means of communication”, the IVS has to verify that the SIM, baseband and RF path are actually usable, and you can’t test that without a network attach.
In practice that’s what all current eCall implementations do. The modem attaches to the cellular network at each ignition so it can confirm it’s capable of placing an eCall. If you block the modem or antenna, the IVS fails its self-test and the vehicle is no longer roadworthy.
Does that mean the modem used for eCall is the same that is used to transmit telemetry? Because that's a level of shitty I hadn't even considered. That said, it would go against the spirit of the law as I read it.
There are always workarounds, of course, but that does pose an annoying problem to patch.