In fact when I lived in Austria, within a couple months I had access to more black market goods/services then I did after growing up in the US for 25 years. I would imagine Germany is the same.
Germans are extremely law abiding and rule following. People are also generally worried breaking social norms.
So while it is technically possible for photographers to digitally alter photos before upload, there will be very few who would dare to do that.
Photographers rely on the revenue from passport photos for their businesses to survive. Initially the plan was to exclude professional photographers too but the government backtracked on that after outcry.
> after growing up in the US for 25 years
and the average lifespan of the species being 12-15 years.