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To be fair, the dev did say that he's only including them because he feels they're an important part of the game and it would give the Switch version the exact same features as the other versions. Yet installing them into the game itself instead of a system OS was one of the reasons the game got a bit sidetracked, so it doesn't excuse the lack of an achievement system in the OS for developers to take advantage of. (optionally like in steam's case, or not like in PSN/XBLA's case) It should still be mandatory to make them have the OPTION in the System OS so that devs can insert them at their own will without going through extra hoops. That's exactly what Steam does, as plenty of games on that service lack achievements while some have them.