That's all talk to say they're abiding by the rules. In reality, that is far from the truth if you actually play the games that are there. To begin with, 18+ or decensor patches already go against Steam's rules, as they bypass Steam's Mature Content Preferences, so it doesn't even matter even if the patch contents abide by the steam rules. They're still not allowed on Steam yet Kagura Games and other h-game devs have been doing it since ages with such workaround. I've played many games including ones published by Kagura Games which focuses on straight shotacon sexual content and some loli sexual content too, including other contents that technically would go against Steam rules. Not a single one of those games have ever gotten removed, so this is just more of a nonsense to control the freedom of artistic expression. It only has a real risk when Karens start complaining about it. Just take a look at the workshop of Wallpaper Engine on Steam and you'll easily find countless amount of "illegal" content aka. content that Steam says they won't allow it on their platform. This game is a lot tamer compared to the hentai games I've played on Steam, so it is just surprising to me you're this afraid of releasing a simple patch outside of Steam. I'd suggest simply dropping the patch at F95 if you really want to be this cautious with your official channels.
I also still remember from my playthough in the past, that one scene in this game where Neus doesn't wear panties under her skirt and while going up the stairs, she flashes a kid. xD
I vaguely recall it was somewhere around when you meet Neus' mature busty version, it was her mom or something.