External TestFlight submission fails with 422 ENTITY_UNPROCESSABLE (betaAppReviewSubmissions), case 30000008195719

Since November 5, every attempt to submit a build to external TestFlight testing fails. App Store Connect shows "There was an error processing your request", and the request POST /iris/v1/betaAppReviewSubmissions returns 422 ENTITY_UNPROCESSABLE. The request is made by the App Store Connect website itself, so there is nothing I can change in it. It happens with two different apps on my account, in more than one browser. Test Information, privacy policy URL, App Privacy and age rating are complete; internal testing works.

My Digital Services Act trader status has been "In Review" since early November and my Paid Apps Agreement is still pending. Has anyone seen external TestFlight submissions blocked with this 422 while DSA or agreements were pending, and did it clear once they were approved?

Developer Support case: 30000008195719 (no reply yet).