I would say that the answer depends on the type of ballast and the instructions on the LED.
In general LED bulbs/lamps that are designed to be connected without any change to the existing ballast will state that in their installation instructions.
If you are asking whether retrofitting a luminaire with an LED lamp requires you to install a ballast disconnect if a new fixture of the old type in that location would require the use of a ballast disconnect device, I do not know the answer to that.
Would you be planning to bypass the old ballast but leave it in place and wired?
Most of the led light has a dedicated ballasts differ than the ballasts used for other types of light and also if the dim actions are required surely you should use the specified ballast by the supplier.
LEDs use drivers not ballasts. The power from the driver is a class 2 circuit, not the shock hazard requiring a ballast disconnect.
But if you keep the ballast and replace FL tubes with LED, then I would say a ballast disconnect is required.
We are using Phillips LED lamps that operate off a ballast, $10 each, about 10 watts.