greatquux, I (and the Exchange Server engineering team) would love to hear more about your clients' scenarios that are management only. If you're open to it, please reach out to me at schnoll @ microsoft.com (spaces put in intentionally) and we can chat about it.
As to your question, previously, software products licensed through Volume Licensing (VL) agreements (such as Exchange Server 2019) were downloaded from the Microsoft Volume License Service Center (VLSC). But the VLSC site has now been retired and replaced by the Microsoft 365 admin center. Customers who purchased Exchange 2019 (and other VL software) also retrieve their product keys from the Microsoft 365 admin center. See https://learn.microsoft.com/en-us/licensing/vlsc-faqs-home-page for more information.