It takes a long time for a submitted article to be accepted, edits done, and finally published in a respected/juried journal (IIRC, mine took 2 years from submission to publication). There is no chance the paper, if it has yet to be submitted, will be peer reviewed and possibly accepted in time to be mentioned in the application. So, IMO, mentioning its being submitted is reasonable. Of course, if you are listing this in the CA activities section, be mindful of the character limit.
Well yeah I’m not saying it’s the same as being accepted, I’m just trying to figure out how much it will help me if at all.