I don’t think that’s correct but I could be wrong. Even though it doesn’t explicitly say that in the Germany Political Situations it does say something the Soviet Union Political Situations section.
Specifically speaking, it states that while they are not at war with Russia;
" (Germany and Italy) may not move units into or through any original Soviet territories or Soviet controlled territories."
Remember that nobody, not even their allies, are allowed to move into Soviet territories, nor can they move out of them. So Germany would have to declare war on Russia in order to move there, even on a ncm.