Surge Protection

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.
 
It's always tricky to gauge what amount of work might trigger an AHJ to require related parts of the electrical system to be brought up to current code. I had an HVAC system replaced on my house and the contractor said an SA had to be installed on my service panel. Luckily I already had one in a collar under the meter, but I needed to point that out to them. A less aware homeowner would have ended up with two SAs on the service panel and lost a 2P breaker position.
 
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