When you upload an APK, it must meet Google Play’s target API level requirements.
Starting on August 31, 2023:
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New apps must target Android 13 (API level 33) or higher; except for Wear OS apps, which must target a version between Android 11 (API level 30) and Android 13 (API level 33), inclusive.
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App updates must target Android 13 or higher and adjust for behavioral changes in Android 13; except for Wear OS apps, which must target Android 11.
Permanently private apps—which are restricted to users in a specific organization and are intended for internal distribution only—aren’t required to meet the target API level requirements.
I get that it’s up to the devs to authorise it. It just seems odd that they seem to require manual review for some apps and others is just a minimum. Perhaps it’s a setting.