Is it possible to test a VPN application through TestFlight with a single developer account?

Question

iOS

I'm currently developing a VPN app for iOS and would like to test it with TestFlight. However, as far as I know, in order to properly test an application with VPN functionality, I definitely need a developer account registered to the company. Quote from the App Store guidelines:

5.4 VPN Apps
Apps offering VPN services must utilize the NEVPNManager API and may only be offered by developers enrolled as an organization. You must make a clear declaration of what user data will be collected and how it will be used on an app screen prior to any user action to purchase or otherwise use the service.

My question is: Has anyone tried using TestFlight for a VPN application while having a single developer account? If yes, what was the result?