According to Andrew Steane's Thermodynamics chapter 19 on Thermal radiation:
"The total emission from a physical object can usefully be separated in two parts: the thermal radiation and the rest. Thermal radiation is the part associated with a non-zero temperature. It is caused by random jiggling of the charged particles of which the system is composed."
The random jiggling is crucial here to ensure the system energy gets distributed amongst the radiation particles in a maximal entropy distribution (the usual Boltzmann factors).
Now Hawking radiation occurs as a result of a black hole having a non-zero temperature and the spectrum has the usual Boltzmann factors (black body spectrum) suggesting it is fully thermalised.
On the other hand the derivation of Hawking radiation works equally for free fields or interacting fields, and the origin of the Boltzmann factors is really just the same as the Unruh effect (an horizon effect), so clearly the "random juggling of charge particles" plays no role in its thermalisation.
Is there an alternative thermalisation mechanism at play here, or is the notion of black hole temperature and thermal radiation just a formal analogy with no statistical physics origin?