Hmm, I do not use backlight, however back in the day when most LCD still widely employed PWM, there were lots of thoughts on the subject. IIRC flickering will cause headaches/fatigue if the cycling frequency is low enough (however low depends on each person), and a very high cycling frequency shouldn't cause any fatigues to the human eyes. Now the only way to know the frequency is using expensive oscilloscope, which I doubt any ereader reviewer would have in their possessions.
I'm willing to test using the forma for a week using backlight; however, I fear I might be prone to placebo/bias i.e. I know it employs PWM so my brain will trick me into thinking that the backlight causes me fatigue

.
Would be interesting in hearing some replies from Kobo on this design choice. One thing I do notice is the 1% brightness of the Forma is much lower than the previous readers, and you also got more fine control in low brightness level (e.g. from 1->11).