On System-Wide Keyboard Shortcuts in iPadOS

Jason Snell in talking about his impressions of iPadOS 13

Users can’t assign systemwide keyboard shortcuts...Arbitrating keyboard shortcuts between the system and individual apps is hard

When I was thinking about this, I had to ask myself, how does Apple make a non-complicated system wide-keyboard shortcut? I think the answer is to follow the "Add to Siri" path.

In iOS 12, when an app has a feature that can be invoked by Siri, Apple supplies a button the developer can add to their UI that brings up a system controlled UI that allows the user to speak a phrase for Siri to save as the "incantation" of that feature. In iOS 13, if you can't verbally talk, you can type your Siri incantation and later you can speak that incantation to summon that feature. So why not take a similar approach where there is a system defined button and UI that allows a developer to show the user they can make this functionality able to be activated via a keyboard shortcut. Of course, in reality, you end up needing to make that code available to be run independently of the app if it's a system keyboard shortcut because your app might be closed. If that's the case, you end up building an extension, and then you've basically built a SiriUI extension.

So now I'm wondering if the answer to system keyboard shortcuts is really just a different way to access single step Siri Shortcuts?