I don't believe any panel needs to be any more accessible than the area it serves.
"Accessible" is a realtive term. Accessible to whom, and for what purpose? I submit that the panel in a home's basement isn't very accessible to the folks on the second floor, or out in the garage.
It's a shining example of common sense to have a rooftop location for the panel serving rooftop equipment- including service receptacles. Why make the guy go up and down the ladder a dozen times in the course of maintenance?
That panel has to be fed from somewhere. IMO, that "somewhere" also has to be accessible.
For me, the principle is 'accessible to the guy who's going to want to use it.' If that means upside-down, hanging from the ceiling ... so be it.
There's another element here: one of identification. A panel right next to the equipment it serves makes it pretty easy for me to find the right switch in a hurry. If I have to climb down from the roof, enter the business, and poke around in several panels to find the 'right' one, its a poor design.