The code in question is in the global scope (outside any functions) and it’s initializing a global variable. Zig doesn’t have C++'s concept of executing runtime code before main() (and thank god for that), so the code will run at comptime, even if not annotated with comptime.
PS: e.g. if you sift through all the noise here: Compiler Explorer, you’ll find the ‘comptime-populated’ array: