Probably obvious to a lot of people, but perhaps not everyone. More and more, modern convenience has made inter-sample overs simply a moot point.
What I'm getting at is that I'm sitting at my computer, where I listen via my Topping DX7 Pro, using its digital gain knob. It's never, ever close to the 0 dB setting, which would be painfully loud even it it didn't overdrive my iLoud MTM amps into saturation. And of course it's a similar situation with people using a laptop or other computer, with headphone or outboard speakers—you're probably using digital control. When I'm listening on my iPhone, the digital gain is rarely full blast except when I'm relying on hearing a conversation on the tiny built-in speakers—for audio listening through headphone and IEMS, it's backed off a few dB.
When working on music, I have a choice of always being at 0 dBFS and relying on analog pot somewhere, but it's more convenient to allow a bit of digital headroom and control it from sitting at the computer anyway. My 20 year-old Acura, which I fitted with a USB interface, is the only place where the phone feeds the USB with no ability to adjust the gain, and the only volume control is the analog one on the built-in stereo (yet it still manages to sound great—my music friends love to check out their mixes in my car, LOL).
But like I said, "more and more", it's unlikely for listeners to even generate such an over in normal listening.
NB: This is just an observation, I'm not saying that music production shouldn't strive to eliminate them, or that DAC manufacturers shouldn't pay attention. And of course I understand giving up a little dynamic range, but in general turning down is just dropping more into the noise floor anyway, and since virtually everything I listen to is 24-bit, there is no practical penalty for "throwing away bits" with digital gain control.