The most common situation where this would affect laptops, in my experience so far, would be a broken driver causing a kernel lockup (not a panic) which triggers a watchdog reboot. That situation wouldn't allow for an NVMe flush.
I mean I grew up diligently turning off my PC by parking the disk and using the various operating system level shutdown procedures. Nowadays I smack the off button, but that still just triggers the OS shutdown procedure. I don't turn my Mac off as a rule, its sleep mode actually works. ish.
REISUB for a somewhat safe EMERGENCY reboot and O instead of B at the end for shutdown.
At least re: this issue; it's still a bad idea because it's only safe if all software is written following data integrity and flush rules to the letter, and most software isn't. You're eventually going to run into issues on any OS by doing that, because most software doesn't get this right unless it's a database. And you're still going to lose data that's in buffer cache, I'm pretty sure that won't get flushed.