Ubuntu only has HVM images for Amazon (https://cloud-images.ubuntu.com/locator/ec2/)
According to Amazon, you cannot create AMI's at all if you're using grub v2, and starting with an HVM:
"GRUB Legacy (version 0.9x or less) must be installed on your instance." (https://docs.aws.amazon.com/AWSEC2/latest/UserGuide/create-instance-store-ami.html#ubuntu_instructions)
But Ubuntu current versions no longer have grub less than v2 (starting with bionic, I believe?).
This seems to be a catch-22, Amazon's insistence on very old grub (which bemuses me) combined with Ubuntu only supporting HVM base-images (which seems a poor decision while Amazon is blocking them). How do I escape from this? :)
UPDATE: Response from Amazon support is that they don't support AMI without EBS any more, so no-one should be using it (and, I guess, they need to update/remove their docs that explain how to do it!)