When you filter the recording at 20kHz the first mirror image you would encounter and have to suppress is 24kHz.
That's why a lot of filters attenuate max at 24kHz.
This allows for less steep anti-alias and less steep reconstruction filters that still can reach 20kHz with 0dB attenuation.
Of course there will always be recordings that will still have some signal above 21kHz or so but that would be very low level so mirror images (and IM products) will be even lower.
Still ... filters as used by Motu, Chord and some of those SW filters of course are 'better'.
Motu goes to 21kHz and Chord to 22kHz.
Inaudible anyway for the wealthy audiophile that can afford the mentioned Chord gear.