I thought that I had tested this with some 2.2.x version of gpg. But if it doesn't work with 2.2.31, then I probably didn't and just relied on the release notes.

FWIW: I tested it with a freshly created card and thus keys. When hitting the "create OpenPGP Key " button, a warning was shown that a key already exists, I selected the do-anyway thing but the created keys had different fingerprints then. Thus the creation time was not taken in account. I recall that I implemented this for gpg-card and thus only for 2.3 - it is just quite likely that it does not work for 2.2.