The current draft states:

To do this, the conformance model prioritizes content needed to complete tasks while still testing the entire view for accessibility errors

How will this work for content-free applications such as WordPress, Drupal, SharePoint, Adobe Experience Manager (and other CMS'es), or applications like Blackboard (LMS) or PeopleSoft and similar web-based tools (applications that may include human resource management systems (HRMS), customer relationship management (CRM), financials and supply chain management (FSCM) and enterprise performance management (EPM) tools)? These 'out-of-the-box' web and cloud-based applications will also need to be able to publish accessibility conformance reports (VPATs being one such form) that is written explicitly devoid of any "content" - as "content" will be added after the fact (after purchase) by the end 'owner'.

Additionally, how will organizations be able to evaluate Design Systems and/or Component Libraries that are intentionally created "content-free" - the primitive building blocks that will result in 'pages' and 'task-flows'? What about 3rd-party "Accessible Themes" for these types of tools as well?

Yes, these tools will still be able to evaluate "the entire view", but because the focus of the scoring model is on content, these tools will not be able to "score" as highly as end products with content, as the scoring model "...prioritizes content needed to complete tasks..."

It would be extremely troubling that a "Completely accessible" out-of-the-box CMS would score lower than the same CMS with additional inaccessible content added to the application.

The current draft does not appear to address this concern.