The measurements are a little confusing since I don’t think they were taken at the same brightness level. iPhone 12 Pro’s PWM frequency changes significantly at different brightness levels.
It says for the Pro Max that, as soon as the device is dimmed the PWM starts (and is likely always at 238Hz, which is typical of Samsung made OLED displays). I interpret that to mean that at anything but 100% brightness there is PWM used.
My own guess is that at 100% brightness, the pulse drops to 60Hz.