Doesn't the first Apple link specifically say the 398-day limit doesn't apply to self-signed CAs?
> This change will affect only TLS server certificates issued from the Root CAs preinstalled with iOS, iPadOS, macOS, watchOS, and tvOS.
> This change will not affect certificates issued from user-added or administrator-added Root CAs.
The second link about the other restrictions (including <=825 days validity) does appear to apply to all CAs.