I think it would be valuable to get pam_limits into common-session. I think the reason we didn't do it back in the day was that we didn't have as clear of a common-session vs common-session-noninteractive distinction.
That said, I think it's way too late in the bullseye cycle to do this. I'm writing to say that as someone reasonably familiar with PAM, I think this is worth doing early in a release cycle where we can shake out the problems. Doing this would probably involve adding in common-session and filing bugs against pam services that include common-session suggesting that they remove. --Sam

