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Yes, changing from Unreal 3 to 4 would be a big undertaking (the two engines really aren't compatible with each other, despite one being the evolution of the other), but we've already seen several Unreal 3 games on Switch.
Rocket League was originally on Unreal 3, but was ported to Switch by Panic Button (who also ported Doom to Switch).
Outlast 1+2 were also Unreal 3, but were ported to Switch in-house at the original developer, Red Barrels.
Granted, I don't know exactly how either of them brought these games to Switch (ported Unreal 3 to Switch? Ported game to Unreal 4? Custom engine entirely?), but the point is that the lack of Ureal 3 support on Switch hasn't stopped them.