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With defaultContentLanguageInSubdir: true, a 404.html file should be created at the root #5161
In the direct relation with #5160 I open this (related ?) issue.
When option defaultContentLanguageInSubdiris set to true, a sitemap.xml file is automagically generated by Hugo at the root of the website, as well as in all language subdirectories.
I propose that the same is done for the 404.html file, which is currently (as of Hugo 0.48) only generated in language subdirectories but not at the root of the website.