Done, I updated the document now. Did a few small tweaks, for example, instead of referencing to DG1 and DG2, I said "other than DG3 and DG4".
Also the EAC section I putted into privacy as its more of a privacy feature than a security feature, and also clarified in the section that only "face based biometrics can be used".
HOWEVER, a future extension is that,
there is the potential possibility for the CA’s to obtain EAC certificates. Since the CAs are very trusted people, even by governments, it could be possible that ICAO is willing to cross-sign some EAC certificates wth a few of the CA’s in the root trust store (mozilla, microsoft, chrome, apple, etc), opening up the possibility to do initial fingerprint verification using a USB-based table fingerprint reader, entirely inside the ACME protocol.
Here is how this would work:
If ICAO "cross signs" a CA intermediate certificate using their EAC root CA key, it means, that a CA could then use the intermediate certificate (or a leaf certificate signed by it) to authenticate to the chip using EAC.
Technically, it could simply work by the CA having to upload the intermediate certificate to the ICAO's website, along with a challenge nonce signed by the intermediate certificate.
ICAO then cross-signs the intermediate certificate, and gives back the signed version, which the CA can then use to EAC authenticate.
This EAC authentication function would then need to be implemented in a future challenge, like emrtd-data-02 which includes a specific "EAC" challenge function that allows the CA to directly talk to the passport's chip using ACME.