Exactly. It is one of those things that Apple conveniently ignores when talking about fragmentation.Fragmentation is already in play. There was a new version of iOS 12 released the other day for phones that aren't eligible to be updated to 13.
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Apple Releases iOS 12.4.2 Update for Older iPhones and iPads
Though iOS 13 has been available for a week now, Apple today released an iOS 12.4.2 update designed for those who are still running versions of iOS 12 on devices that aren't able to be updated to iOS 13.www.macrumors.com