The answer comes down to the cost of failure and subsequent damage due to it. This includes the transformer that has failed, possible personnel hurt or killed due to the explosion, possible fire, environmental oil spill, projectile emission of steel, hot copper, bushing porcelain, etc.
Consider a set of four transformers set close enough to each other that the failure and fire on one could easily place the remaining three in danger of damage and failure. Consider these serve a hospital where lives depend on having adequate power available, or a production facility that for loss of primary power supply will mean shut and loss of product and production that could run in to millions. Trans Diff clears the failed transformer long before any eruptive failure. TD along with sudden pressure relays usually cover almost everything not protected by some thermal relay system.
Size of the transformer is a small consideration and transformer differential protection may be added to any transformer, so it comes down to what is the justification?
Hope this helps.