It's not the issue that torp bombers are too strong against subs. The issue is that subs are generally too weak.
T1 subs are complete rubbish. I wonder if someone could take pure stats on how much frigates are being build in every naval maps compere to subs. Most likely t1 subs wouldnt even be built in most situations on all naval maps regardless of their size and player count.
They have no role in this game. They lose to every unit with torps except what? Wagner? T3 sonar?
EQ fixed that years ago. FAF didnt even bother to make it less worse. Because the point you start looking at naval balance and adjust t1 subs you will realise t2/t3 phase is way too unbalanced with different unit rosters for each faction (the way torp defence works is also a factor). I highly doubt someone in FAF team would do something this big.
...or if someone would just copy-paste EQ in FAF.