It's not up to the implementation to decide whether to pass by reference or not, but it is up to the implementation whether to use pointers under the hood to model passing by reference. Since there's no pointer arithmetic, other models could theoretically be used to accomplish the same semantics [0], it just happens to be that pointers are by far the most logical choice.

[0] As a silly example: a JavaScript implementation could technically store object references as a URL of an API that allows interacting with the object, as long as this is transparent to the user and the program behaves the same as a pointer implementation (minus non-functional characteristics like performance).