I don't think so, the matching rule actually requires the surrounding environment to be the same for the matching paires, in the processing, the diffusion density or metal/poly density around the matching pair will actually affect the matching device themselves, without dummy diffusions, it is hard to guarantee the source/drain diffusion of the matching pair are doped identical.
so unless you can leave ~2u white space (90nm process), dummy transistors(not dummy poly only) are required.