Surely this is up to the company? They make a decision as to whether to pay somebody to work after-hours versus the business they lose by not doing so.

I specifically took a job that didn't require after-hours work (I have a family which I prioritise) and we did upgrades in working hours. Once in a blue moon a site would be down for a minute or two, but the trade-off was obviously worth it for my public sector employer which generally struggled with recruiting engineers.