They just need to be installed at the opposite end from the main supply, so that the loads are in between both sources, and current on the busbar is subtractive, rather than additive, in order to take credit for the 120% rule on a panel with loads. It's common that this means it is on the bottom, but on a bottom-fed panel, it would be on the top.
The rule the OP is questioning, is the requirement for the hold-down kit on a backfed breaker. This applies for backfed breaker, but grid tied inverter breakers have an exception, due to the fact that they are only grid-following, and not grid-forming. If you unplug the breaker, the grid ceases to be within spec, and the inverter(s) will shut down right way. The reason for the rule for a hold-down kit, is to prevent popping a breaker energized from its load side, which could still have voltage at its terminals after removal. Grid-tied inverters don't fit within this intent, since they are a current source that follows grid voltage, rather than a source that produces its own voltage.