Both the theme and the plugins are sourced in `oh-my-zsh/oh-my-zsh.sh`, so technically there should be no difference.
But a theme should only be used to change the appearance and a plugin is there to add new functionality.
With appearance I mean setting the values of `$PS1`, `$PS2`, `$RPS1` and etc.
There are some plugins which also set some appearances, like the vi-mode plugin which sets the right hand side prompt (`$RPS1`) when it is not already set.