Don't the premises "AirTags are only allowed in checked bags if they're turned off" and "AirTags can't be turned off" lead to the conclusion "AirTags aren't allowed in checked bags"?
Sure. Just like a bazillion other coin cell powered nrf52 devices. Or like a coin cell powered digital watch. Would an F91-W be allowed in checked luggage? Perhaps not, not unless there is a specific exception. And if you ask some policy communication employee, they won't make up exceptions, they'll apply the rules at hand.