The relevant code rule is:
680.51(A) Ground-Fault Circuit Interrupter. Luminaires, submersible pumps, and other submersible equipment, unless listed for operation at low voltage contact limit or less and supplied by a transformer or power supply that complies with 680.23(A)(2), shall be protected by a ground-fault circuit interrupter.
680.23(A)(2) Transformers and Power Supplies. Transformers and power supplies used for the supply of underwater luminaires, together with the transformer or power supply enclosure, shall be listed, labeled, and identified for swimming pool and spa use. The transformer or power supply shall incorporate either a transformer of the isolated winding type, with an ungrounded secondary that has a grounded metal barrier between the primary and secondary windings, or one that incorporates an approved system of double insulation between the primary and secondary windings.
The Low Voltage Contact Limit is: 15 volts (RMS) for sinusoidal ac, 30 volts for continuous dc .
If you can't find a 24VAC GFCI, you may need to change the transformer and lights to 15VAC or less using a transformer identified for pool/spa use. If you could find a listed pool/spa power supply that is 24VDC (fixed, not just rectified pulsating DC), the lights may not care about the DC source. Could be an excuse for a new LED retrofit.