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On Windows, utimes, lutimes, sceKernelUtimes and futimes open a FILE_WRITE_ATTRIBUTES handle and only then encode the times. A time the host cannot represent returned EINVAL without calling SetFileTime, and with NTFS last-access updates enabled closing that handle set the file's access time to the current time, so a rejected call still changed the file and guest_file_timestamps failed on "access time preserves microseconds". A rejected time now marks the handle with 0xFFFFFFFF, which SetFileTime documents as preventing operations on the handle from updating the times, before the handle is closed. Error order is unchanged. Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>