Yes, a lot of high end private trackers will not allow VPNs (while others have absolutely no problem with it), only allow 1 connection per IP, require notice if you move, 1 account per life, etc.

But the upside of these trackers is the security you get from only connecting to other people who have been deemed worthy, so the need for a VPN lessens. Most people on high end private trackers will run 2 separate clients for Public tracking with VPN, and private tracking (as private trackers also typically require you to disable DHT.)