For starters in order for a manufacturer to have their cases MFi certified, it needs to be able to withstand a drop of at least 1m over hard surfaces, at least that’s what sources are claiming. This includes all orientations, even if it were to fall flat on the display. The rules also state that cases must offer a buffer of at least 1mm between the display and a flat surface should the phone fall display-first.
For the most part, most cases already fit this description, although there are manufacturers out there who create cases more for aesthetics and not so much for protection. These are cases preferred by some users who are more interested in protecting the back of their phone from being scratched as opposed to protecting them from drops.
This means that companies looking to have their products certified might have to resort to new designs and thicker and heavier materials, but is that really a bad thing? After all what good is a protective case if it doesn’t protect, right?