You don't only need the account, you need a phone that is locked down with hardware components and cryptographic keys that attest it hasn't been modified "unauthorizedly". Where the authority is not the device "owner" but Google, Apple, and the manufacturer
The account would be easy enough with fake data and a 10€ prepaid one-time-use phone number. Finding an exploit in Android such that you can turn off Google's tracking but not trigger their "you modified your device" scans (that are to be tied to your government identity verification continuing to work) is a game I'm not looking forward to playing.