I suppose higher efficiency would be a benefit for ATX PSUs, couldn't you theoretically make a higher wattage PSU with the same size as Si based ones. I know that GaN chargers can have higher wattages and smaller size than Si based ones.
The current 80+ Titanium is already hitting the ceiling of what PSUs are physically capable of and there isn't much left. The current 80+ Titanium 96% efficiency is extremely high and the closer to 100% you get, the harder it is to achieve. Especially since 100% can't be ever achieved. So, that would only leave 97%, 98% and 99% efficiency levels. And i don't think 99% efficiency level can be achieved either.
GaN is most useful where there are actual space restrains in place, like mobile chargers and such. Also, those chargers are simple devices, taking the AC and converting it to DC (usually 5V) with at fixed power output level (e.g 50W).
PC PSUs, in the other hand, have three main voltage rails: +12V, +5V and +3.3V. On top of that, PSU has to provide fluctuating power output, depending on what components need at any given time. This will complicate things even further. Meaning ATX PSU needs far more internal components than simple mobile charger. And one just can't shrink the components down, to get overall smaller dimensions, while keeping the same wattage output.
I suppose people with SFF (Small Form Factor) power supplies might benefit from higher wattage ratings in PSUs smaller than ATX, especially if they're trying to upgrade to a higher power GPU.
High power consumption hardware = lots of heat. Put that into small PC case and you are seeing thermal throttle 24/7. So, 1+kW PSU, regardless the efficiency level, isn't worth for mini-ITX builds.
Also, mini-ITX builds are niche market regarding desktop PCs. Not to mention that SFX PSUs usually cost more than their ATX counterparts. Now, if you build a PSU out of GaN fully, that will jack up the price even more. And it's the price of GaN, which has kept it at bay thus far. Since it's very hard to find those buyers, who are willing to pay far more for a PSU.
E.g, would you pay double or triple the price for a GaN PSU, that is SFX in size, has efficiency a bit better (let's say 97%) but wattage wise is same as standard ATX PSU?
Heck, even at current date, despite there is plenty of options, most people don't care about PSU's efficiency. 80+ Gold is usually the choice nowadays, but why not buy 80+ Titanium PSU instead? Sure, 80+ Titanium unit can cost 1.5-2x times more than 80+ Gold unit. So, if even current day 80+ Titanium units are seeing hard sales, why would anyone buy GaN PSUs, that cost even more than 80+ Titanium units?
At current date, most SFX PSUs go as high as 750W. SFX-L as high as 1kW (Corsair has one such unit). While ATX PSUs go up to 2050W (consumer grade, e.g Silverstone Hela 2050).