The license for the DVD version is with the actual disk, the license for the offline installer is with the GOG account.
GOG has essentially created a way to bypass their own licenses, as a feature. And it looks like they won’t be affected by this law because of it.
They haven’t created anything.
They just don’t allow games that use DRM (any kind of license check as a prerequisite to run software) on their store. Packaging a game with DRM is an extra step.
In the legal sense that having DRM-free software does not mean that you’re legally entitled to use it, sure.
But checking for a license before running is literally the entire definition of what DRM is. They aren’t “bypassing” anything. They didn’t create technology. They simply refused to allow software that has any type of license check (DRM).