Good point Greg, the exception does only state lighting outlets.

I don’t really like the idea of only one tenant having exclusive access to the smoke alarms circuit breaker anyway. If that tenant goes out of town for several days and for some reason the breaker trips, there could be an issue. Also, what happens if they move out and power is turned off to that unit?
I haven’t done an existing two family conversion in several years, but the last time I did one, I wasn’t allowed to have the two units interconnected. What I was allowed to do was have interconnected smoke alarms installed in each unit, supplied from each units own panel, keeping each unit separate. Then I extended one additional smoke alarm from each unit in each of the common areas, like the hallway, stairway and basement laundry area, basically giving redundant initiation in common areas.
Maybe the rules have changed. If so, it sounds like a house panel might be the only solution, possibly even if installing a low-voltage system.