That's a relatively recent RFC; there are ISPs which have been using CGNAT for longer than that, and they do use RFC1918 addresses for their CGNAT (for instance, I know of one which used something in the 10.x.x.x range for CGNAT, which works in practice since most domestic networks use something in the 192.168.x.x range).
RFC6598 defines CGNAT IP space as 100.64.0.0/10 (https://datatracker.ietf.org/doc/html/rfc6598). RFC1918 (private IP space) is a different allocation.