There's at least one condition not related to the sex chromosomes that can result in someone being genetically XY but being apparently female in every other way, although I'd think being completely immune to testosterone would make them a terrible 'ID-SOL', and would probably give them a totally unremarkable life, except for a brief popular news article with no followup: 'hey this ID-SOL had a female child! (oh wait, she's infertile and genetically male and has no special abilities... nevermind.)'
The 'it's incredibly rare, so it won't be approved' thing probably still applies even if this is possible, and even though female Nepleslians aren't too rare to begin with anymore. On Earth, only 2 to 5 people in every 100,000 who are genetically male have complete androgen insensitivity syndrome, and those numbers might be even smaller (down to 0) due to previous genefixing, especially any attempts to keep it out of the ID-SOL population.