SATA SSD has a huge heatsink attached to it. It is crucial for 24/7 use. NVME needs active cooling to survive.
Lots of consumer SATA SSDs don't have any thermal pads between the PCB and the case, and plastic cases are common. Heat just isn't a problem for a drive that's only drawing 2-3W under load.
And most consumer NVMe SSDs don't need any extra cooling for normal use cases, because consumer workloads only generate bursts of high-speed IO and don't sustain high power draw long enough for cooling to be a serious concern.
In the datacenter space where it is actually reasonable to expect drives to be busy around the clock, nobody's been trying to get away with passive cooling even for SATA SSDs.
Are any SATA SSDs actually built to sink heat into the enclosure? e.g. The 860 Pro released in 2018 has a PCB taking up a third of plastic enclosure with no heatsinks to speak of: https://www.myfixguide.com/samsung-860-pro-ssd-teardown/
And even in worst-case hammering of drives, thermally throttled NVMEs can still sustain higher speeds than SATA drives.