Can text buttons fail 1.1.1 and 3.3.2?

Hey folks,
I've just opened an issue about this in Github:
https://github.com/w3c/wcag/issues/985

I would appreciate what input you could give us. The ACT Task force seemed
kinda split on this, so it would be great if AG could weigh in on this
conversation.

Kind regards

-- 
*Wilco Fiers*
Axe for Web product owner - Co-facilitator WCAG-ACT - Chair ACT-R