Meanwhile the t70 is laughing.
Armor way higher than the AEC isn’t saying much. That’s like saying “moving accuracy way better than ostruppen” lol. There’s also effectively almost no difference as almost anything on the axis side that isn’t small arms will penetrate both vehicles 100% of the time.
I think by 4cp counters are definitely on the field and it wouldn’t need be an unreasonable time for it to come out, and stuff like the luchs, aec, t70 and Stuart are all on the field by 3-4 cp but 5cp is still probably better timing. I really do think it’s fairly comparable to the t70 in terms of role and type of vehicle (they even have the same recon mode now).
T-70 needs teching and has close to half the armor/less Hp.
The armor of the Valentine is higher than any other light tank and should be classified as meduim/light. Actually it makes quite a difference since the AEC dies to AP rounds (and to one tellar mine) while the Valentine takes little to no damage, so you are actually wrong.
At CP 4 the only thing that counter a valentine from Ostheer would be a pack or shreck and I doubt that either of the would be able since Valentine is one of the fastest tanks around.
For OKW only Puma would be able to counter it but even then it would have to be the first unit out of T2 leaving OKW without a Luch. Even the Puma might have trouble chasing the Valentine due to terrain speed modifiers.
The unit should actually become better armorer and far less mobile since (in real life it was infantry support tank and not cruiser tank) having one of the fastest tank with bonus vision roaming around and calling barrage will probably prove problematic.
Its vet bonus should also be looked at since gaining speed and size reduction combined with "war speed" make the vehicle ridiculously fast and with extremely low target size.