I have a 32 GB iPad, I think it's the year 2020 model. The OS alone uses 19 GB ("iPadOS" 12.3 GB + "System Data" 6.4 GB) so yeah, not much chance doing any OTA updates on that one with the requirement of 13+ GB free.
Maybe some day the fruit company with all their billions will be able to innovate a solution for deploying for example browser fixes so that they can be installed without requiring tens of gigabytes of free storage on the device. Meanwhile, we're stuck using a computer and iTunes for that.