AFAIK, it has the same thermal solution as the previous generation, a heat pipe connecting the fan and heatsink. That being said, anything remotely taxing the system will start the fan up, and it get's fairly audible. But I guess that's better than the Air which is thermally constraint with it's heatsink only and case fan. I wonder what performance we could have seen from the 2020 Air had Apple included a heat pipe connecting the fan.