Dug out the Clara HD with 4.38.23038 and it works on there.
- Go to home screen (not really needed but convenient)
- Tap on the search icon
- in where to search, Kobo Store, My Books, My Articles are tested to work
- Type devmodeon in the search box (all lower case)
- Tap on Go
- The search will return no results found
- Close the search window
- Tap on More on the bottom line of the screen
- Tap on Settings
- Tap on Device Information
- The last item in Settings will now be Developer Options (for the Clara HD, 3 pages of them)
I did not test this with SideLoadedMode enabled or other attempts to bypass registration. Since this is supported on 2 Kobos with 3.38.23038 and 1 Kobo with 4.37.23028, I feel safe in saying that it will work on any Kobo when you enter the correct term in the search box.