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LWG clarified in its 2019-03-01 teleconference that "Mandates" just means there is a required diagnostic for violating the rule. In some cases, this can also be achieved by SFINAE yielding an empty overload set, for example. Error messages are often better with static_assert, though.
Saying that it is expressly unspecified whether the "ill-formedness" is in the immediate context or not, i.e. is SFINAE-able or not.
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