You'd be wrong, I'm afraid.
I tested it, and it does in fact work. Gohma tile one, plus five, all blank, and it was invisible.
I also tested Manhandla, tile one blank, minus four all blank, and the pincers were not invisible. Those seem to be hardcoded, which is probably a bug, nit 'new' enemy tiles should fix that.
Floating Gleeok heads should also be good, as they use a 'special' tile, but I didn't test them. They may be like the Manhandla claws. I'm also unsure about neck segments.
Still, EE invisibility would be better, if it had additional flags to disable it with items.