While this is obviously anecdotal, there's an account over on Reddit of a guy who suffered a grand mal seizure who also owned an iPhone XS. Once out of the hospital, he started having 'focal seizures.' Once he read about the XS PWM and all that, he turned off all the stuff (require attention, face ID) and reduced his usage, and they stopped.
https://www.reddit.com/r/apple/comments/co9eof
From what I read, only a small subset of the population that suffers from epilepsy is triggered by flashing lights; and supposedly, of those, the vast majority are sensitive between 3-30Hz, with some up to 60Hz. I believe the PWM is much higher than that, so ostensibly it *shouldn't* trigger it.
With that said, I'm told by people that it's in my head that the phone's bothering my eyes....even though I'm absolutely fine if I don't use my XS, and even though I can look @ it for 10 or so minutes and feel eye strain and headaches coming on.