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I can provide confirmation, Ben: https://www.w3.org/WAI/tutorials/forms/notifications/
On the linked page, under the "Example 4: Listing Errors" subheading, it recommends that errors should be at the top of the page, before the form. Furthermore, under the "Approach 1: After Submit" subheading, it also recommends to set the focus of the page to the first errored input field. Currently, neither of these things occur with the current system.
Testing will likely occur within the next couple of months.
Aharon, can you please provide confirmation that this has broken WCAG compatibility? When is testing set to occur?