The "wink and smile" here is in relaxing the 110.26 violation when you put a disconnect in a closet. Whether they would extend this to a sub panel is questionable. Having a single OCPD in a disconnect box seems OK though.
The other place I see the "readily accessible" violation is when the air handler is hanging from unistrut in the garage ceiling. They generally have the disco up there too. That is great for the servicer but you can't reach it without a ladder.
There seems to be a lot of flexibility in the location of air handler disconnects, even by the same guy who will walk around the condenser disconnect with a yard stick.
The same seems to be true of water heater disconnects. They often show up in closets or in a corner of the garage where 110.26 can't be met, even before the homeowner starts bring in his stuff.
I suppose if I was a code nazi I would insist that the customer had the sub panel or disconnect in the hall outside the closet but still close enough that you could see someone approaching it from the water heater.
Buy a picture to cover it up.
