> Beginning in macOS 10.14.5, software signed with a new Developer ID certificate and all new or updated kernel extensions must be notarized to run. Beginning in macOS 10.15, all software built after June 1, 2019, and distributed with Developer ID must be notarized
So, no. You need Apple's approval to be able to create software that can actually be ran by end-users even if you do not distribute using the App Store.
How can you notarize your software when apple has suspended your developer account? Would you not say that notarization requires you to have a developer account, which requires Apple's approval?
> Beginning in macOS 10.14.5, software signed with a new Developer ID certificate and all new or updated kernel extensions must be notarized to run. Beginning in macOS 10.15, all software built after June 1, 2019, and distributed with Developer ID must be notarized
So, no. You need Apple's approval to be able to create software that can actually be ran by end-users even if you do not distribute using the App Store.