AFAIK it is not possible as long as Devise's default validations are used by declaring the following on the authentication model:
devise :validatable
In order to use error message variable interpolation in Rails with YAML locale files when using Devise, all validations have to be declared manually and the ones provided by Devise have to be deactivated.
When trying to override a single existing validation, Rails 3.2 fails during initialization. So it's an all in or all out when using Devise validations.