Yes, but creating an AFCAD simply as a means to classify yourself as a developer so that the other 99.99% of the time you use the product
You can easily say, and it's generally true, than before you might be able to create an AFCAD, especially from scratch so you wont include anyone elses code, you have to use the product for quite some time, to learn it properly. Nowhere they say that previous experience with FSX, or any other flight simulator program, is required to join the program.
And, nowhere they say you can't subscribe just to evaluate your chance to eventually become a professional developer, they would have provided a different (time-limited) subscription, or a trial version, if evaluation needs weren't covered by that program.
It's a very broad license, and LM has been very clever to set it up that way, which really means the only requirement to join the developer program, is to have a credit card...