Disconnecting, yes. But overcurrent is another matter entirely. And the topology of the transformer, can redistribute a secondary overcurrent on an individual phase so they are in the blindspot of the primary OCPD.
240.21(C) only allows a primary OCPD to act as protection for secondary conductors, for qualifying topologies that keep currents lined up between corresponding phase conductors. If you had a qualifying topology on a 208V:480V transformer, this would mean a 400A primary fuse at 208V, would effectively act on the 480V side as a 173A fuse for the secondary. Qualifying toplogies for this, are delta:delta 3-wire, and single phase 2-wire to 2-wire. A wye system and any system with a centertap will not qualify, and requires secondary overcurrent to meet 240.21(C).
The way I read these rules, it is telling you that you don't need to protect the transformer from overload caused by the inverter, because the inverter is current limited by design. However, one thing this rule doesn't clarify, is how it is meant to interact with 240.21(C). The transformer doesn't require protection from the inverter, as long as it has enough KVA (unlikely that it wouldn't). But the secondary conductors still require protection, which this rule doesn't tell me otherwise. Assuming you have a wye system on at least one side, I see as requiring a secondary side fused disconnect, or circuit breaker, to meet 240.21(C) in one form or another.