Key word here is "Should"
Sure you can‘t definitely say that a mosfet reaches that temp, it‘s only an approximation. They only assure junction to case thermal resistance, the junction to ambient depends on how the fets are mounted on the board, how many layer the pcb has, the ambient temperature or if there are heatsinks or fans used. So it depends on the Mainboard manufacturer and the user.
The junction to ambient resistance of 49 degrees of the low side fets are for example measured with the fet „Surface−mounted on FR4 board using 1sq−inpad,1ozCu.“ like the data sheet says.
But I think this should be approximately the situation on a Mainboard plus/minus a few degrees.
Plus/minus a few degrees at about 70-80 degrees isn‘t that problem for a mosfet with junction max temp of 150 degrees.
And I agree, I also wouldn‘t buy a board completely without any heatsink on the mosfets. But even my MSI Z370 Gaming Pro Carbon with heatsink on vrm throttles in OCCT benchmark, using AVX512 with small dataset, cause of reaching too high vrm temps. It has only 4 real phases and a vrm with more than 4 real phases is definitely better if your goal is really high oc.
Or if the vrm is using power blocks (high side and low side fets in one package) or power stages (high side/low side and gate driver in one package) or as in the case of many b450/x470 boards high side/low side fets and driver as separate chips. The power stages, especially that from IR are one of the best here in terms of efficiency and power loss. Another thing is if they fake the phase count by doublers or they use twice components for every phase. Here you have also to look which one is used. In terms of conduction losses the use of doublers is better than the use of twice components per phase.
So the heatsink isn‘t always the guarantee to reach higher oc as a board with 8 real phases and power stage mosfets without heatsink will maybe better overclock than a board with 4 real phases and cheap fets with heatsink.
Edit:
Here is a link to the Gigabyte Ultra Durable technology:
As you can see they use several 2 oz copper layers in their PCB design, so the mosfet junction to ambient resistance should be at least at the same level as the OnSemis testing scenario or rather better.