Due to overwhelming support from animators, Actions are no longer
created with fake users by default. If you're mainly creating action
libraries (the primary use case and argument for having this, mostly
used for creating a set of motions for games or perhaps to use in
NLA), you're really in the minority here.
For the most part, fake users just lead to heaps of "dangling" actions
in files which newbies (and even experienced users) may often be
unaware of. Since Fake Users are really more of an "opt-in" system
everywhere else (i.e. when creating Material Libraries), the same
should applied for Actions and creating Action Libraries.