The tricky part is that that exception that says the CEE doesn't have to be used in "existing buildings or structures" if the concrete makes it inaccessible. So if I pour concrete without remembering to make a connection to the CEE then I have an 'existing structure' with an inaccessible CEE. Grounds rods here we come.
What I've mostly dealt with is inspectors not acknowledging the existence of a CEE unless there's a job card showing it signed off in a special place before the pour. Which is the flip side of requiring it to be done before the pour, let alone requiring extra measures to install a CEE if the pour happens without a proper GEC to CEE installed.