It mainly depends upon the load, rather than the motor.
For a propeller, the torque at zero speed is (effectively) zero, and you don't care if it initially jumps backwards a bit as the speed controller first fires fully open loop. Because the torque is low at low speeds, an purely open loop commutation sequence is very likely to drag the prop along too, meaning enough speed can be gained to enable a high enough Bemf to be reached to enable the system to swap into sensorless closed loop control.
For a motor say driving a car along, that's rather different! (there can be max torque at zero speed, and you don't want the car to jump backwards or forwards when you just want to inch forwards slowly......)
It also can depend upon the motor control strategy being used. Simple block commutated controllers, or voltage controlled sinusoidal voltage control ones can get away with basic phase position sensing, whilst systems running advanced strategies, such as FOC are likely to have physical position measurement systems for improved accuracy and failure effects management etc