Electroplated nickel CAN flake, like on pistols. The process starts with a thin copper plating on the steel, which makes it easier to actually electroplate with nickel. It’s not trivial to electroplate copper onto steel (it requires a cyanide bath as the electrolyte), but once the copper is bound to the steel, nickel will bind to the copper. This is the crux of the matter: if there’s a flaw in either the nickel layer or the copper layer, and anything gets to the copper itself, the plating breaks down. And that flaw could simply be holster wear.
Modern cartridge cases are electroless plated; this is a purely chemical reaction that applies a controllable thickness of a nickel alloy evenly over the entire surface of the part. It should not be able to flake, since there are no intermediate layers. It CAN wear through, though. I have some old cases that have been cleaned so many times that you can kinda tell they were once nickel, but not so much now.