Starting on November 15, 2024 @Steam will no longer display games to customers in Germany if the game is missing a valid age rating.

nanoUFO@sh.itjust.worksmod to Games@sh.itjust.works – 66 points –
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Older titles should be restricted to +18 by default, at least they would stay purchasable.

Don't know if they can legally pretend it has a rating though

You are probably right but there has to be some kind of path forward baked into the regulations.

It will be a bit of a farce if retro gaming becomes illegal because no one submits the paperwork for 8-bit consoles.