Blank_User said:
No. Loli/shota are for characters that appear preadolescent. Though it's pretty close to loli, this character has small breasts and significant pubic hair growth, so I say she's not quite young-looking enough to count. Also, official age plays no bearing into this.
Read the loli and shota wikis for more information (you can still view the wikis even if you can't view the posts).
Breasts and pubic hair don't necessarily disqualify something from being loli, and the latter isn't even present on the child post, so if nothing else there's even less room for debate there.
Loli/shota are primarily focused on proportions, and I don't think it would be unreasonable to expect anyone looking at those posts to perceive that as a child, pubic hair or no. I think there's a decently strong argument for both of those being tagged loli.