Plus some more recent models. eg the PD-A600 or PD-ES600. Shimano say they are designed for road / touring etc, equivalent to Ultegra.
The big problem with a lot of clipless pedals, and a fair few flats these days tbf, is they don't have an obvious or easy way to attach reflectors. A lot of jurisdictions have a requirement for pedal reflectors. Sure you'd have to be having a really bad day to be nicked for not having pedal reflectors, but still, in event of an accident, a not completely 100% road legal bike could cause you liability issues down the line.
It's one of the things I like about my M324's, they take normal pedal reflectors, with ease.
I have those clip-on platform things on my hybrid (which probably does the most dark urban riding), because that meant I could continue to use a set of M520s with a broken mechanism on one side. They're fairly rubbish as platforms (they do work for keeping pedalling with your SPD shoe unclipped on the towpath on approach to wandering dogs), but the reflectors do an admirable job of staying attached.
My mountain bike has double-sided SPDs for being able to clip in quickly reasons, which precludes reflectors. I have QRD pedals for the Brompton, and the flats have reflectors, but I tend to use the SPDs more. On both these bikes I've stuck Scotchlite on the crank arm on the basis of complying with the spirit, if not the letter, of the law.
On the recumbents reflectors are academic (like panniers, you can't legally use a recumbent after dark), though I have covered the underside of the single-sided Look pedals with Scotchlite, because there's no good reason not to. I'm not sure how visible they are that close to the front light, though.
From experience of spotting cyclists on the road, both as a cycist/pedestrian and driver, I reckon the value of pedal reflectors is mostly that they're the one rear-facing reflector still attached to unlit BSOs. As soon as the cyclist is properly lit, they don't really achieve much, other than marking those distant light sources as 'pedal cycle' (which can also be achieved by flashing lights or distinctive patterns of reflectives such as those on clothing or Ortlieb panniers).
So in practical terms, I don't worry about them from a safety perspective. In the unlikely case that someone tries to argue the contributory negligence angle after a collision, I reckon having good lights is a pretty strong counter argument, but ultimately it's the lack of helmet that will carry more weight.