Thanks for creating the report, but please stop arguing whether it's a bug or not. It's not clear from the spec and since we don't have an implementation of this to check against the TCK, we don't know if this is a valid interpretation. The behavior for "owned" associations you are referring is apparently valid, otherwise Hibernate wouldn't be JPA compliant. For non-owned assocations, we don't know yet. So, provide the PR, and then we can talk about details