Yes and in all the references, when using less than 150 m it is the RVR value required. It does not specify that pilot observation is allowed in this situation.
The place where pilot observation may be used is specified in table 1 of para 3 EUOps 1.430 and is at note 3 remembering that this table only goes down to 150m.
In order to operate at 125m see para 4 which then gives the requirements and does not mention the exemption in note 3 of table 1 and as stated in para 4 (i) E, RVR is required.