I said usually not definitively since there will always be that one obscure case someone will use even though it's knowm it's impractical to encounter in daily life. But please go to common/local stores or websites and find high saps 10w-40's. I don't have to say the same about 0/5/15w-40's you can easily find a high saps one nearby.
You can go look at the back of 10w-40 bottles to make sure they're definitely not licensed with approvals that are high saps. If that 10w-40 bottle even has any specs listed on the back of it whatsoever since it's an old viscosity for new vehicles to spec and obsolete for new vehicles at least in the americas. Most 10w-40's will have none or old specs listed on them. Old enough to where the oil spec desired to be used in said spec'd engine is old enough to where a bad cat wouldn't matter. They'd usually be old enough to be emissions exempt anyway.
The SAPS limits as enforced by the API (which are really just Phos/Zinc limits) don't apply to xW-40's, that's why M1 FS 0w-40 can be SN.
With Euro-geared lubes, which actually do have formal tiers for SAPS (Low/Mid/Full) Mobil 1 ESP 0w-40 (also: Corvette) is low SAPS (hence the ESP designation).
If we are looking at non-Euro lubes, the SRT 0w-40 is your typical SN/SP Energy Conserving additive package in a 0w-40 format.
M1 High Mileage 10w-40 has 800ppm of Phosphorus, 900ppm of Zinc, which is higher than most of the Mobil 0w-xx oils. M1 FS 0w-40 has 1000ppm, 1100ppm while the low SAPS ESP oil is 900/990. The ESP (low SAPS) 0w-20 is 880/950 while EP and AP 0w-20 are 650/750.
10w-40's don't have any real formal approvals, so the bar isn't all that high for performance in service, quite unlike the case for the Euro 0w-40's, which have to meet extremely demanding performance requirements from the myriad of OEM's the product carries the approvals for.