Since the removal of the term lighting and appliance panelboard yes. Before then (2005 NEC I think) it depended on what those breakers served.
Common example I once had pointed out was baseball field lighting - was common to have 5 light poles with 50 amp 120/240 feeders to each pole. They would use a main lug panel and have the 5 service disconnects - was code legal. Then someone would come along and want to add a 120 volt receptacle to that service panel - now they turned it into a lighting and appliance panelboard just by adding that one circuit and it required a main. A way around that was to supply a sub panel then the 120 volt receptacle circuit from there - though it seemed pointless. But today it would be ok without the sub panel.