I'm aware that for airtags, the implementation should not be too bad. I'm talking about iPhone which are much more important.
They can also be tracked close to real time with their gps coordinates so it cannot be passive, the phone has to report somewhere. And it's reporting in the background, there's no indication that its doing it.
Admittedly I have nothing to back this up, but judging by how well designed Find My is in this aspect, I'd be surprised if the implementation for the self-reporting one is that much worse, I suspect the re-did it in iOS 13 when Find My launched.
Was it ever possible to access your iPhones location through iCloud.com? I know Find My Friends was available there, but I don't remember if "Find My iPhone" was.