Proposed resolution (approved by CWG 2022-12-02):

Change in 9.2.6 [dcl.constexpr] paragraph 7 as follows:

A constexpr specifier used in an object declaration declares the object as const. Such an object shall have literal type and shall be initialized. In any constexpr variable declaration, the full-expression of the initialization shall be a constant expression (7.7 [expr.const]). A constexpr variable that is an object, as well as any temporary to which a constexpr reference is bound, shall have constant destruction. [ Example: ... ]

[Accepted as a DR at the February, 2023 meeting.]

According to 9.2.6 [dcl.constexpr] paragraph 10, a constexpr variable must have constant destruction. However, 7.7 [expr.const] paragraph 7 only defines constant destruction for objects, not for references. Presumably constexpr references should also be able to have constant destruction, and any temporary object to which such a reference is bound should also be required to have constant destruction.