You probably can and it won't be nearly as bad as what it is on MacOS. You only need a code signing certificate for drivers from Microsoft. You might not even need that if WinFSP provides signed binaries and you don't modify the driver part.

(Source: until 2 years ago I used to work at a company that did that using a proprietary driver - CBFS - and was looking at WinFSP to replace it.)