The api stat page is not up to date and how complete dlls are is not easy to guess. Just because a function is not marked as a stub in the spec file doesn't mean it is not a stub. A lot of functions are stubbed in C code. Further a large amount of functions are 'function pointers' in COM objects and for that reason also aren't counted. Only people who know dlls well can make good estimates. A while ago we thought about dropping the page altogether. Not sure why it didn't happen or else we could attempt to update it.