It's more of a matter of the fact that the unfused disconnect is only tested on its own at 10 kA, and isn't "co-tested" with the breaker manufacturer to take credit for the KAIC rating of the breaker as its SCCR rating. The manufacturers have tested for series rating with fuses of particular fuse classes, but not with breakers. The 10 kA default rating of unfused disconnects is more of a matter of lack of proof otherwise, than a prediction of failure. There may be no physical consequence of overlooking this, but a rating is still a rating, and the NEC and OSHA require complying accordingly.
The unfused disconnects have the same blade assembly, same handle, and same housing as their fused counterparts of the same brand & otherwise-same configuration. The essential differences is the lack of fuse holders, lack of factory-installed neutral, lack of neutral bonding screw, and lack of a "suitable for use as service equipment" rating. It is likely that the manufacturer allows you to use it in series with a set of upstream fuses elsewhere in the circuit, that are of a class that would be compatible with the fused counterpart. So if you had a set of fuses in a switchboard where the branch circuit originates, which then lead to the disconnect in question, it could be acceptable for it to be unfused depending on the fuse class, despite an available fault current in excess of 10 kA.