I believe you are thinking of the requirement that panels supplying circuits (with a neutral) smaller than 30A are considered lighting and branch circuit panels and therefore require a main breaker.
215.2 Minimum Rating and Size.
(A) Feeders Not More Than 600 Volts.
2) For Specified Circuits. The ampacity of feeder conductors shall not be less than 30 amperes where the load supplied consists of any of the following number and types of circuits: NEC 2002