Yes. If you land a #12 conductor on the load side terminals of a breaker, then those terminals are the point of supply of that conductor. If the breaker is 25A, and there is no upstream 20A or smaller breaker, then the overcurrent protection ahead of its point of supply is 25A. Which is more than the 20A limit in 240.4(D). Therefore, the conductor would be a tap conductor, and will need to comply with the rules in 240.21(B).
There is a slight circularity in the way these requirements are written, as the ampacity of the #12 AWG is 25A if it and its terminations are at least 75C rated. So in applying 240.21, we need to understand that the overcurrent device referenced is one sized to comply with 240.4 excluding 240.4(E).
Cheers, Wayne