Due to overwhelming support from animators, Actions are no longer created with fake users by default. If you're mainly creating action libraries (the primary use case and argument for having this, mostly used for creating a set of motions for games or perhaps to use in NLA), you're really in the minority here. For the most part, fake users just lead to heaps of "dangling" actions in files which newbies (and even experienced users) may often be unaware of. Since Fake Users are really more of an "opt-in" system everywhere else (i.e. when creating Material Libraries), the same should applied for Actions and creating Action Libraries.