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I just tested it out. I opened the NES emulator while connected to the wifi and it worked, then I turned on airplane mode and opened it again and it still worked. So maybe they changed it because I remember a while ago I was playing Punch Out at home and got a flight the next day, took my Switch on with me, tried to start the game and it wouldn't load because it wasn't online.
The only annoying thing about the NES emulator is you have to be online to load a game so can't play it on a plane or similar.