Does not meet definition of scrimmage kick formation:
A scrimmage kick formation is a formation with at least one
player seven yards or more behind the neutral zone, no player in position to
receive a hand-to-hand snap from between the snapper’s legs, and it is obvious
that a kick may be attempted
Although it doesn't meet the definition of a scrimmage kick formation, that does not exclude blocking below the waist from being illegal:
During a down in which there is a free kick or scrimmage kick, blocking below the
waist by any player is illegal except against a ball carrier.
The kicker and snapper are not protected in ways they would be if this were done from a scrimmage kick formation.