When developing any film in any format, the primary principle behind agitation is so that fresh solution is brought to the emulsion, moving away the depleting solution that was in contact with the film. So, yes, you need some form of agitation...whether lifting film holder out of solution and then placing it back (in the case of vertical hangers) or in tray processing. Rocking/sloshing the tray should be sufficient.
A very long time ago I used to process a stack of sheetfilm, pulling the bottom sheet out and placing it on top of the stack, a continuous leafing action thru the entire stack, for the entire processing time. Kodak agitation assumed sheet films agitated 1x/min., and you could do continuous agitation by adjusting the developing number by 3 (similar to assuming 74 degree processing rather than 68 degree processing)