The DC side is permanently energized in sunlight, even when the AC is shut off, and you'd need to cover it with an opaque tarp or wait for sunset to shut it down completely. Anywhere that NEC2017 and later applies, the NEC effectively requires devices that shut off the outputs at the module level, with an allowable standby voltage of up to 30V after shutdown is initiated, for communication and diagnostics purposes. The NEC doesn't explicitly state that you need module-level rapid shutdown, but if you read between the lines in 690.12, the voltage constraints imply module-level rapid shutdown. Theoretically, you could connect sub-30V modules all in parallel instead of series and still comply with this rule despite no shutdown at all on the DC side, but it is unlikely you will ever see this in practice as very few (if any) products exists that could work this way.
Generally, one disconnect, strategically placed, is permitted to satisfy multiple requirements with the same device. It is common for utilities to require an outside-mounted disconnect, and it is logical for this device to double for rapid shutdown initiation. Your fire department may require additional locations to initiate rapid shutdown, but the NEC alone has very simple criteria for what kinds of devices qualify. See 690.12(B)(2)(C). For a system capable of off-grid operation (islanding), you may need a separate switch dedicated to rapid shutdown, as it would continue to operate its off-grid loads if all you did was shut off its connection to the grid-tied side.
The previous installment of rapid shutdown in NEC2014 was extremely vague on what kinds of initiation devices were intended, what location requirements they have, and how many (if multiple) would be permitted. It's a good thing that 2017 has more guidance, so everyone involved can understand the intent.