That is changing. I've noticed over the past couple of years that sites that could be accessed with JS turned off are now showing a "Please enable Javascript to continue" (Quora) or just hiding the content entirely (Business Insider).
Not surprised. When paywalls started becoming a thing most of them could be circumvented simply by removing a DOM element and some CSS classes. Nowadays this is basically not possible anywhere anymore.
I'm sure there are other examples as well.