German here. I've actually first heard of the new law through this thread and having done a little bit of research on german sites, we could be in for a pretty frustrating piece of legislature . It's still very vague, but it could be that games might be shadowbanned in a way that could make it hard for a German to even learn of their existence, let alone buy them on Steam directly. We'll only know for certain how things are once the law arrives.

This will hardly affect AAA or even AA titles, but with something as small as Touhou fangames, developers might not have learned of this (or assume that they have a more than negligible amount of customers in Germany).

If it's really just a simple on-site form with no caveats that Neetpia has to fill out in time, I'd love it if they did. I've greatly enjoyed Gensokyo Defenders as well as the past demos of The Touhou Empires and would be eager to buy it day one.

rest assured. we as community work hard...to save some older games. that goes for touhou games as well. we already contacted the devs of your stated games...we try to raise the rate of age rating in the next weeks. :D