it probably depends on if the gamecard reader firmware does its own checks too. the cfw doesn't reimplement that I dont think? on 3ds it works because only the os validates cartridges, but on switch the gamecard reader has its own firmware that atmosphere doesn't really modify (and I don't know if the gamecard firmware is even accessible from the os side, so it might not be possible to patch it either. and it wouldn't just be loaded in memory available to be patched either considering it's a different chip that handles gamecard reads)
it probably wouldn't be impossible to modify the gamecard firmware and install a custom gamecard reader firmware that would bypass all checks, but I don't know if that's documented yet. it would break the reader on ofw but you wouldn't care about using game cards on ofw anymore anyway