According to SQL:1999, it shouldn't be possible to write:
INSERT INTO tbl (a, b, c) DEFAULT VALUES ...;
Since UPSERT/REPLACE is syntactic sugar over a variant of INSERT .. ON CONFLICT ..., then I assume that one should also not be able to write:
UPSERT INTO tbl (a, b, c) DEFAULT VALUES ...;
The INSERT RFC and UPSERT/REPLACE RFC's EBNFs, as written, allow for this. The RFCs don't go into details about what this means with the insert column list when using DEFAULT VALUES -- therefore, it looks like a bug.
The EBNF should probably follow SQL:1999's more closely. See partiql/partiql-lang-kotlin#1666.