401(a)(26) when Participation is frozen

• a plan is frozen in 2022 - both accrual & participation are frozen, and
• the plan is not underfunded - not qualified for 401a26 exemption
• at the same time, there are some employee meet the eligibility requirements before the valuation date which means they are eligible to enter the plan if the participation is not frozen

in this case, should these employees be counted as non-excludable employees in 401(a)(26) (ignoring the minimum participation relief in SECURE Act)?

appreciate all replies and helps.