I assume it is universal but any permit pulled in Lee County Florida will go through plan review. It may just be a rubber stamp but it can also be kicked back if it does not include the things they require. That is where the decision would be made if a panel upgrade triggers AFCI installation.
Of course if this gets done without a permit I am not sure who would be there to tell you AFCIs would be required. It is certainly not going to be a home inspector. They are not legally able to cite code unless they are licensed CODE inspectors. Florida does not even recognize "home inspector" as a regulated industry and their "inspectors" are just informal advisors with an occupational license. A home inspector can advise a client of anything they want, down to their favorite color for the toilet but it has no force of law.
