Help with a unique orbit with a 23 degree tilt where the tilt stays on Y axis

I’m trying to recreate the earth’s orbit around the sun. The earth is tilted 23.5 degrees and no matter where in the orbit it remains tilted along the Y axis.

But no matter how I try the tilt wants to follow the sun object (it’s parent) so the tilt is always 23 degrees from the Z axis, which is not how our earth’s tilt behaves.

I’ve tried a few different things and none have worked.
Key framing exact tilt every 40 frames = crazy flipping object
Following a path instead = no change tilt still is attached to sun object