I would assume the number varies based on the age, design, brand & capability of the panel & its batteries.
In one building they've had to replace a system as the building needs several more sounders due to partitioning, but the panel can't take any more devices on it's available circuits.
Another building I've visited has a similar problem with being expanded as far as possible with extra modules power supplies and bells (which surely use more power than electronic sounders?)and is so stretched it could fail.
So it appears (this is from engineers reports, different companies, different regions) that there is a finite capacity as to how far you can add to a panel with sounders and that some panels cannot be extended this way at all.