It's an interesting fuzzy gray boundary between the Ubuntu on Windows and "emulation". It's still built as an NT sub-system (like Interix was), and it's still the NT kernel ultimately in charge of everything. The difference seems to be the NT kernel implementing the generic POSIX standard versus the NT kernel implementing the specific system calls of the Linux kernel. So on one hand it is an emulation because there are specific real world binary behaviors (and quirks and bugs) it's trying to replicate, versus implementing standards from a specification document, but on the other hand, it still seems to be the NT Kernel doing NT Kernel things.