No, for night duties of over 10 hours an appropriate fatigue risk management applies. Guidance for that is provided in GM1 CS FTL1.205 (a) (2).
A FRM compliant with ORO.FTL.120 is only required in two cases: reduced rest and crew members in unknown state of acclimatisation on a longer FDP.
Additionally, the approval of FRM is not a stand-alone approval. FRM, if required, is approved as a constituent part of the IFTSS approval.