Any tool that can dump cartridges from a Switch or 3DS can also dump installed files. Cartridges are the exact same files under the exact same encryption as installed eShop games are. Anyone who actually wanted to emulate those systems while still being a good customer and paying for the games could very easily do so.

Switch 2’s piracy/backup “tool chain” is very limited and immature, and as of earlier this week is now only viable on a limited set of outdated firmwares and requires a lot of external shenanigans to get the initial entry point. It’s a lot less accessible, even though the process works for cartridges or installed files.

That said, every article like this that says “you must dump or provide your own ROM” is just saying “we aren’t going to provide links to the pirate site hosting the ROM”. The dumping process removes DRM from the files, so anything you could do with your dump can also be done with a copied version of someone else’s dump.