I disagree for several reasons.
Firstly, if PS is not an EMS tech, then Sasuke stands no chance against Naruto.
On a more serious note, several quotes make me believe that Madara was capable of PS before his death.
Madara says he will show them 'the full power of Uchiha Madara.'
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If he said 'my full power', then I'd agree PS needs rinnegan. But he's referring to the legend here, and that legend was established when Madara was still alive. In other words, he's about to show them why he was famous.
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Not as important, but the stabilizing thing shows that Madara is fully aware of what is the maximum power of the tech he's using. This makes me think that he's used it before.
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'Did my grandfather really fight against this?' Frankly this quote could go either way, but I'll include it anyways. Should be self explanatory.
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Multiple quotes from this page.
1. 'If I'm the only one here the extent to which the maps will need to be redrawn won't be too drastic.' Clearly, Madara has fought Hashirama in map-changing battles before. However, he hasn't demonstrated any EMS techs capable of this - except PS.
2. 'This is Uchiha Madara's strength.' Same reasoning as for 'the full power of Uchiha Madara.'
3. 'Then why at that time...What kind of adult...' Onoki directly asks why Madara didn't use PS when they fought. Madara doesn't say, 'because I didn't have the Rinnegan.' Madara has been quite honest for the time we've known him. He gives praise where it's due, to Hashirama and to the 5 kage. He acknowledges that he was beaten by Hashirama repeatedly. It doesn't seem in character for him to lie in order to make others believe him to be more powerful than he is. This is probably the strongest evidence I have.
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'One slash of it's sword...only the bijuu...' These are oddly specific claims for someone who ostensibly has never used this tech before.
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'Gave birth to a completely new Doujutsu.' Madara has not yet demonstrated any completely new eye techniques. Itachi and Sasuke have done everything Madara has, except PS.