That would cause major issues in areas where phones are forbidden for national security or sensitive equipment reasons from having antennas active. I've never heard a report that a manufacturer has even considered that idea as it could potentially cost them major damages.

Of course, that's not something that a legitimate manufacturer would have in their standard firmware.

However, that is a possibility for specific malicious firmware uploaded to some "phone of interest" to prevent its user from protecting themselves by turning on airplane mode.