Anyhoo...I agree with you.
But I also strongly believe that it isn't as simple as saying "bounded accuracy".
I don't think anyone would describe PF2E RAW as bounded accuracy. Taking a game that isn't bounded accuracy and simply subtracting a factor across the board doesn't make it one. It may make the basic mechanism of establishing the D20 modifier superficially appear similar. But bounded accuracy informs the design of 5E throughout, whereas it informs nothing in the design of PF2E.
We just got confirmation that the rules and guidelines for not adding your level to checks and DCs basically amount to...
Not adding your level to checks and DCs!
From Paizo's forum:
TriOmegaZero said:For the most part, that appears to be the case. Proficiency bonus just becomes a +2 per rank, then subtract the level of the subject from the stats you normally add proficiency to. There are some GM notes on adjusting encounter XP and treasure as well.
The-Magic-Sword said:They take up about a page, the basics are simple- just yank level out of all the stats that have level, it gives you a list in a paragraph. But they also provide a simple DC chart for no-level, and a new Creature exp chart along with an explanation of how it changes encounter building, there's also a warning about treasure since its much easier to defeat higher level foes so your party may get way more, it even suggests using another variant for automatic item bonus progression when using it.
I really don't have anything else to say. The main difference between 5E and PF2 (as regards "accuracy" and whether it is bounded or not) is that level is added to everything in one of those games, and now you can play PF2 without. (In fact, just as I suspected, you could do that all along, even without Paizo's written guidance.)
Provided, of course, you don't mind performing subtraction on-the-fly to almost every number in the game.
For some people, that's no bother. For others, nothing short of a reissued Bestiary with all those numbers already recalculated on the page will do.