I've had an rPi4 running a copy of a forum and server (for reference) in one of the fancy aluminum cases which passively cools for a couple of years now, no issues.
Yeah I should have been more specific, a fan isn't the only option but you need either a fan or a cooling case. Running them naked is too risky now
The big chunky aluminum ones do seem pretty good on the pi 4. I had one in the flirc case for a long time and it never seemed to have issues. Obviously adds to the cost though. Also not sure if the Pi 5 works as well in them given its higher thermals, and the Pi 4 didn't exactly run cool so imagine the 5 might throttle occasionally without active cooling.