I've had a couple custom actions (Kelbly & Trophy) and had and still have a couple trued 700 actions & 1 XP100 action and they all shot under a quarter inch - indoors. Some matches I shot a couple groups under 0.110" and some matches I had a hard time shooting under 0.500 groups at 100 yards.
Along with the action - you need that match grade barrel capable of those bug hole groups, proper bedded action in stock (sometimes need to bed that puppy a couple of times), a scope with sufficient power and thin crosshair so you can hit a house flies eye and a 2 ounce trigger such as a Jewell trigger.
To consistently shoot under a quarter inch - you need good equipment plus you need to possess outstanding shooter skills.
If a person can consistently shoot 1/4" groups on demand - they might consider shooting hunter and benchrest matches, as those boys are great to be around and one could trade information back and forth for the benefit of all.
I have a 22 centerfire wildcat that shoots under a 1/4" indoors all day long - yet I missed several fat prairie dogs at 300+ yards this summer - no problem missing with an accurate rifle - I know it wasn't the rifle or ammo's fault.
Myself, I will take a good custom grade action over a factory action trued up if given a choice every time, but I also know a trued up action done right will shot just as well and there are a few box stock rifles out there that will shoot bug hole groups also - they are rare and a gem if you have one.
For a good recoil lug - especially if you shoot switch barrel rifles - this one was initially made by the great riflesmith, T.J. Jackson and it holds zero every time upon barrel change! He called them 1/2 moon recoil lugs and a lot of competitors in Texas went to them, just as fast as T.J could turn them out. Tremendous competitor, riflesmith and overall great person and friend - he's been missed for several years.