There is no requirement to place a OB AFCI or GFCI in the first outlet. The only requirement for replacements is to protect the outlet you are replacing. You could put them in each outlet replaced. Probably not a great Idea.
Good point, lets put it in context with Charlie's kitchen remodel.
Its new work only, where Arc-Fault code 210.12(B/D)(2) demands an AFCI breaker, or AFCI Plug at first outlet. My AHJ interprets first outlet as first readily-accessible outlet 210.12 (2nd sentence), since reset buttons shall not be buried behind appliances or cabinet doors.
While Kitchen remodels may get new circuits & new-outlet locations; triggering the new-work codes; 210.12 for AFCI's, 210.8 for GFCI's, 406.12 for Tamper Resistant device, and State Energy Codes for new lighting, other Small Appliance Branch Circuits may just get replacement plugs.
406.4(D)(1-5) A/GFCI protected & Tamper Resistant plugs are only needed where replaced, if required by current new-work codes. For those unmodified existing circuits with some devices replaced, and existing grounding wiring, the original plugs behind appliances, cabinet doors, and the wiring in-between can remain unchanged, grandfathered with the original construction.
Electricians not equipped --or interested-- in finding the first outlet in a circuit, will first upgrade the electrical-service box to fit modern A/GFCI breakers. Then when nuisance tripping A/GFCI breakers won't function thru cross-circuited renovations and jury-rigged building wiring, they must face the prospect of every outlet being an expensive reset device, or removing the A/GFCI protection all together.
Without a desire to find the fist outlet and wire it for down stream plugs, these Electricians are not equipped to protect ungrounded 2-wire cables with a localized GFCI, as permitted for several years in 406.4(D)(2). These electricians exploit people into complete building re-wiring using new cables with grounding. Both methods pass inspection if done properly, one just offers a lot less protection and cost a lot more.
Electricians equipped to find the first outlet, and properly wire A/GFCI plugs, offer options that avoid exploit, avoid unintended consequences of MWBC's, and other existing-wiring issues incompatible with A/GFCI breakers at the fuse box.
Nuisance tripping with appliances is a learning curve, and having the skills to cover several plugs from one counter-top reset device offers another option to put the AFCI or Dual Function inside, rather than forcing people to walk outside in the dark to reset breakers. These options are not available with electricians who up-sell unnecessary construction to avoid wiring outlets.