"The English Speaking Achievement Test for Japanese Junior High School Students" (ESAT-J) was introduced to contribute to levelling up public English education in Tokyo in 2022. Critics, however, have made claims in the mass media against the use of the test and stakeholder groups have called for its cancellation. This paper presents an analysis of the criticisms using a recent version of the socio-cognitive framework. The analysis reveals that criticisms concern the Development, Measurement, Theory-of-Action (TOA), and Communication Arguments to differing degrees. In particularly, this study highlights the necessity of developing concrete TOA and Communication Plans to guide development and implementation of reform-based tests.