Most definately, but you know how it is, logic sometimes works in mysterious ways. Another odd regulation (also 1941) is the one that banned a single 1939 EK2 in stickpin form. The reason given was that an EK2 could easily be mistaken for an EK1. This doesn't appear to have been a problem with the 1914 pieces, which can be encountered as singles or doubles (9+9mm or 11+9mm). There is one major problem though i.e the lack of contemporary regulations.
This regulation doesn't mention size and the next info (to my knowledge) is from Nov. 1944, which is referring to the 9mm only in stickpin form. It makes sense if the topic was 16mm EK's as stickpins, because the contemporary sales catalogues clearly label them as EK1, but if the intention was 9mm, it would have been just as easy to use the 1914 arrangement. Finally, I've never seen two 16mm EK 1939 as a stickpin combo.