@stefan yes. For operating systems like FreeBSD and illumos, you can have Boot Environments. If you have access to the host, sure, you can “rollback” from there, but that might not always be the case.
If you do have access to the host, it still help with single file restoration, and you get compression and checksumming as a bonus.
The only case where I use UFS instead of ZFS for a FreeBSD VM is temporary VMs for one day testing. ZFS All The Way.