Thanks, Medved.
And even the small draft of air behind the fixture counts.
That's what I though too and rather used ~4mm spacer pads to create extra space above the fixture to open all mounting holes.
(The original fluorescent electronic ballast didn't need such a care and could last there with a 40W lamp (+ its own heat) for almost 30,000 hours. The unevenly drilled holes (by me) used to be above the plastic lamp base that had used to crack by the heat. Last 2 lamps with this precaution EOLed without the cracked base.)
Normally this construction is good, if the air can flow arround the module (so if the cover glass is not sealed, if it is eithr sitting on a metal body with air flow underneath or if the air gap onderneath is open to the surroundings).
The module is attached by those 4 magnets (~25mm long). That's the space above it. The plastic diffuser is avg. ~4cm underneath. Drilling some holes into it would definitely help the air to flow better but holes aren't the thing I wish to look at all the time.
The module wasn't so expensive (compared to native LED panels with the same lumen output) and it's super easy to replace it with another one so if it lasts only a half of the rated life, I'm happy.