Is this not really related to BVAL-221 and could be not solve both in the same way?

I don't think it is related except for the fact that you need to do addNode(null) to create a bean level node.

but is addBeanNode (or addEntityNode) not misleading since we not really add a node?

This does add a node. Check http://beanvalidation.org/1.1/spec/1.1.0.beta2/#validationapi-constraintviolation

When an association is traversed:

a Node object whose name equals the name of the association property (field name or Java Bean property name) is added to Path.

We could make the node creation implicit like I described for BVAL-221 but that's orthogonal I'd say.

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