A solar cell could never achieve the Carnot limit, so the 95% number is not relevant. In order to extract the maximum amount of power from a solar cell, must operate it at it's max power point. When you do this, the cell is in forward bias and must emit light (because of the physics of absorption/emission). Emitting light is a loss mechanism and thus people take this into account when calculating the theoretical efficiency for solar cells. It has nothing to do with currently available device on the market and is just accounting for how solar cells work.
