I honestly think the kernel interface is by far the easiest part of building a MacOS compat layer. The userland is gigantic, super complex, and totally closed source. That's the hard part.
AFAIK all macos software only talks to the kernel via userland APIs - so there's no particular benefit to basing ravynOS on XNU anyway. (Just the opinion of a layman.)
The Mach APIs are available to userland applications, if you used a different kernel you’d have to implement them somehow