We get into that with air handlers in a closet, pretty common since they won't let them go in the attic these days. They put the disco in the closet and there is no way it is 110.26 compliant. Some AHJs require an additional disco in the form of a lock out device on the panel breaker. The disco in the closet is for the HVAC tech and the LOTO is for the electrician.
Other times they just let it slide. It all gets back to whether a disco is any harder to work on than any other switch.
This is another one of those things that will start an argument at an inspector meeting.