If they removed TWP yes. Otherwise it would be way too good. In fact, I´ve got the strange feeling that the new StugG might be a bit too effective at sniping medium tanks now with the increased penetration and TWP.
It's garenteed to get penned by essentially anything that shoots at it, so it's a bit of a glass cannon which I think will balance it out. It's also got a forward fixed gun which means pathing with it can be an absolute nightmare sometimes.
It's in Ostheer T3 meaning all of it's counters will hit the field before it does so I don't there will be much of an issue, I mean USF's AT gun will finally be useful since Axis will need to rely on medium armor now instead of Tigers.