There is no single “correct mapping of abstractions” from the KNX domain to HAs language, but it seems a bit WTHish to me that it is not possible to define HA devices from KNX elements, only HA entities.
I realize that this is probably related to a general ambivalence in HA on the “device vs entity” definition, and that this definition is still evolving. For instance Device Registry | Home Assistant Developer Docs defines a device as “a physical device that has its own control unit, or a service”.
And as mentioned there is no single correct mapping from KNX, for instance my 10 output light thingy could be seen as one HA device or as several devices. And my room controllers could be defined as single devices or as a switch and a thermostat and a presence sensor for instance. My point is that I would expect to be able to configure “virtual devices” the way I want, which would then be treated as devices by HA just as any other device.
It is possible that there is nothing particular to KNX here, maybe what is needed is a general mechanism for configuring virtual devices, somewhat like template entities, only devices. I have not really thought this through yet. But, WTH