the electrode's active surface is the area accessible to potential and/or current disturbances. In this case, your proposal assumes that the electrode is completely acive.
To add to Naima's answer, which is correct -- a lot of folks will measure electrochemically active surface area (ECSA) using capacitive techniques. These techniques also have their flaws, such as assuming a certain specific capacitance for a given material. Depending on the morphology of your electrode, it might be quite challenging to determine exactly what portion of your material is accessible -- and even then, technically there should be a distribution of activities at those sites rather than simply binary "active" vs. "inactive." As long as you explain your loading or characterization method in a way that is reproducible, and ideally so that your metric is comparable to some standard benchmarks, I'd say you're fine.