We tested it on iP12, iP12 mini and iP12 pro. Four devices can work all together (every device has 3 sessions so 12 sessions). After adding fifth device we are receiving NIError.Code.activeSessionsLimitExceeded. Devices are working on 14.8 and 15.0.
Apple documentation https://developer.apple.com/documentation/nearbyinteraction/nierror/3571288-activesessionslimitexceeded?changes=_8 says:
"The maximum number of concurrent Nearby Interaction sessions may vary across device type and platform."
Maybe someone tested it on iP13 with iOS15?