Yes, you will need a self leveling layer to ensure it's is flat and level before the overlay. With the ones I used the overboard system on, the concrete was already leveled so all that was needed to do was DPM then fix the wood to the floor.
The original floors were leveled concrete, DPM, 20mm styrene then P5 with the floor on top of that. We lifted the chipboard, and removed the 20mm styrene. Replaced the DPM then fixed the P5 to the crete base. Then the overlay boards were fixed to the P5, UFH fitted and then the final floor layer was added.
Any reason you don't want to use a traditional screed, you certainly have that option with that amount of space.
I must admit though, the overlay board approach is very good. Fast heat up times and no need for protracted running to maintain a thermal mass.