Technically zero is possible, but as kind of a silly Easter Egg, the accuracy is replaced with the Danny Rensch surprised (pog face) emoji instead of saying zero.
I'll use that react emoji at the bottom of this post to show you which one. On a related topic, this game review "accuracy" is called CAPS and I discuss it a little more in-depth in this video:
What is the worst possible accuracy score you can get after a game review?