It's not the case in my situation. We set "to" field in the payload.
The exact behavior in my case:
1. send the push notification WITH TTL=3 hours
2. push notification delivered to small amount of users (~700)
3. several hours of delay (18-30 hrs and gets longer over time)
4. push notification delivered to the rest of the users (~ 100,000-200,000)
We can't work with FCM in current situation, especially when TTL is ignored.