15, dishwasher manufacturers can't assume the dishwasher is on a 20.
Trying to run a resistive heater on the same circuit as a fridge compressor without tripping leans towards very conservative wattage
Just a waste of copper and a beaker really.
Kitchens in general have required 20 amp general purpose circuits since at least the early 80s. However the NEC (but not the Canadian equivalent) allows for 15 amp duplex receptacles on 20 amp circuits so home builders looking to save a few pennies often use those. Besides, there are few if any, residential appliances out there that have NEMA 5-20 plugs. Then again hardwiring dishwashers was pretty common up until recently.