Of course not. It says *nothing* about whats on disk, because durability wrt system crashes (not process crashes) is not part of the POSIX. So, any behaviour better than full data loss on crash is a robustness property of the implementation.
I argue that a robust useful filesystem should give data-before-metadata-on-rename guarantees, as that would make it a better filesystem. And without this guarantee I'd rather use another filesystem for my data. This is clearly not a requirement, and important code should still fsync() to handle other filesystems. But its still the mark of a "good" filesystem.