How will dct:language be used in practice? In the reference document, it is said to be expected with instances of dct:LinguisticSystem. Are the ISO 639 standard codes falling in scope of this class? In practice, I expect that dct:language will be used with simple string codes from ISO, like "en". But using a literal in places where a string is expected could create issues in the RDF/OWL technological stack. It could just be simpler if no class was formally expected for dct:language.
This issues has been reported by Antoine Isaac:
http://joinup.ec.europa.eu/mailman/archives/dcat_application_profile/2015-August/000298.html
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The draft is quite clear, but it goes against a lot of established practice, and I've seen a guideline draft for DCAT-AP, which used the codes as literals, so indeed the draft must be made super-clear :-)
Analysis: The draft is quite clear that the values should be references to the MDR Languages NAL and not codes from ISO 639.
Proposal: Add a note in section 8 to highlight the fact that all occurrences of dct:language must have a URI as their object, not a literal string from the ISO 639 code list.