Sometimes you manage to catch some of these early on, but often they aren't caught until later in the process -- at which point the cost for the change (and the impact on budget/timeline, and potentially even the very architecture you set out to fix!) is drastically higher.
I've seen it happen a number of times where the 'spec' seemed simple enough at commencement & throughout most of the project; then you'd have each department test & the reports would start coming in... and the result would inevitably be a multiplier on the project scope.
Not from missing features mind you, but via the omission of 'complexity handling' / business logic which was documented -- but the code itself was the documentation, which isn't overly unusual (and IMO isn't even a particularly bad thing in many cases, though not all).
Code-as-documentation is best-in-class at staying up to date, when it comes to documenting what a system does and how. Often the relevant pieces are very discoverable as you're going to make a change. For other goals, it's much less discoverable. Clarity depends on both how the software is written and who the audience is.
Tests-as-documentation are arguably a special case of code-as-documentation. Outside of the case of well maintained tests-as-documentation, code-as-documentation often has a hard time expressing "why" and distinguishing between what has to be a certain way and what just happened to be that way.
It also has some trouble expressing aspiration - "we've decided it should be this way, but it's not yet".