If a server is authenticating via a
certificate and the client has not sent a "signature_algorithms"
extension, then the server MUST abort the handshake with a
"missing_extension" alert (see Section 9.2).
Currently code doesn't send this code as "missing_extension" alert is not even on a list of alerts
Draft of TLS 1.3 says in 4.2.3:
Currently code doesn't send this code as "missing_extension" alert is not even on a list of alerts