/bin/sh is NOT required by POSIX, they explicitly warn that it may not exist[1].
> Applications should note that the standard PATH to the shell cannot be assumed to be either /bin/sh or /usr/bin/sh, and should be determined by interrogation of the PATH returned by getconf PATH , ensuring that the returned pathname is an absolute pathname and not a shell built-in.
I don't know if this is still a thing, but I distinctly remember when playing around with NixOS years ago that `env` was the only thing in /usr/bin, which I assumed was pretty much exactly for this reason.
if you have /usr/bin/env