Posted before I saw this comment. Yes passive cooling is fine with recent firmware and a good heatsink case. I have stress tested with the following case for hours with all cores pegged at 100% and there is no CPU throttling with passive cooling. They do run hotter, but they do not throttle. Old firware and bad cases will though.
https://www.amazon.com/Geekworm-Raspberry-Computer-Aluminum-...