Unless something has recently changed, every MA code class I’ve been to in the past, they’ve always said NO to AFCI’s being required on a panel change. If you add a new circuit, then Yes for that circuit. If you are replacing a panel, that is not a new branch circuit installation or a change to the existing branch circuit.
The AFCI requirement in 406 doesn’t even kick in until 2014.
IMO, the requirement for GFCI protection found in 406.4 also only applies when you replace a receptacle, so you would not be required to install GFCI’s on the existing branch circuits on a panel change either, although most of us usually will.
