No. But...
It's ultimately up to the AHJ to decide when to enforce the relatively recent requirement for a surge protector in the main panel. That requirement applies to services and would most likely (and in my experience) only be enforced on new construction or service panel upgrades. That said, if the AHJ wants to enforce it on any permit whatsoever, they can do that by choice or as allowed by a local rule. But, there is nothing in the NEC that would make it kick in specifically for PV systems and not other work, such as, for example, installing a new subpanel or appliance. Requiring it for PV systems and not other work when the main panel was not upgraded would be discriminatory and would be something I'd push back on.