In Voyager, he’s shown to have pips. In fact, switching him over to Command mode shows a deliberate animation of pips showing up on hid collar.
The EMH is never shown with pips on Voyager. The “ECH” was shown with pips appearing on its first appearance, however:
spoiler
The entire ECH subroutine was created as the result of The Doctor’s daydreaming, so the visualisation of a rank appearing out of thin air makes sense in that context.
The only other time the ECH mode was used in a genuine emergency (Season 7, Episodes 16/17), he did not have pips.
Solution: don’t read that shitrag. It was always a waste of paper, now it is a waste of bandwidth as well.