User blog comment:Hayashi H/Yasen CA Medium Gun Test/@comment-26154973-20160308062145/@comment-26486243-20160308081242

Other way around. The last info I was seeing from Qunow's sources indicate:
 * CL2 is rolled first (which always hits)
 * If CL2 fails, roll for CL1 or CL0 based on enemy's eva and friendly accuracy
 * If CL0, scratch if special attack, else deal 0 if single attack
 * If CL1, scratch if below armor roll, else damage = damage - armor roll

So CL2 is supposed to be independent of accuracy. Another source indicated it is also independent of morale.

At our current 10% accuracy figures the critical rate is about 8%, which indicates that this model is likely true. In the more logical (but not actually true) situation that a critical roll is made only after accuracy is rolled, it should be closer to 10% of 10%, or 1%. The critical rate is currently in the wrong order of magnitude for that model to be possible.