I am not so sure. But my code book is not handy, and I am working from memory, and might have this wrong. I think that if the location of the fridge is such that its receptacle could never be construed as possibly serving the kitchen countertop, and it therefore just like any other wall receptacle, then it does not have to be on an SABC, and it can share with lights.
Someone please check me on this detail: do the receptacles (if any exist) that are (let us say) 18" above the floor on a kitchen wall that does not have a countertop need to be on an SABC?
I think it has to be on SABC or a dedicated circuit:
210.52(B)
(1) Receptacle Outlets Served. In the kitchen, pantry,
breakfast room, dining room, or similar area of a dwelling unit, the two or more 20-ampere small-appliance branch
circuits required by 210.11(C)(1) shall serve all wall and
floor receptacle outlets covered by 210.52(A), all countertop
outlets covered by 210.52(C), and receptacle outlets for
refrigeration equipment.
Exception No. 1: In addition to the required receptacles
specified by 210.52, switched receptacles supplied from a
general-purpose branch circuit as defined in 210.70(A)(1),
Exception No. 1, shall be permitted.
Exception No. 2: The receptacle outlet for refrigeration
equipment shall be permitted to be supplied from an individual
branch circuit rated 15 amperes or greater.