I thought I'd check the guidance in the 3rd edition of the guide to see if they were planning to clarify this situation. It seems the guide authors agree with my position on this
This is precisely the method we've been using, and while this new guidance is still only in draft form, I'll take it as sufficient evidence that our interpretation and application of the guidance is valid and safe.
An a.c. switch or combination of switches must be provided for isolation and maintenance in the installation.
A switch for mechanical maintenance shall be provided in close proximity to the Inverter and shall fulfil the following conditions:
switch all live and neutral conductors
be securable in the OFF position only
clearly show the ON and OFF positions and be labelled as ‘PV system – main a.c. isolator’
An accessible means of isolation shall be provided to isolate the a.c. circuit. MCB’s, RCD’s and main switches installed in accordance with BS7671 and in an accessible location can be used to fulfil the requirements for an accessible mea ns of isolation.
This is precisely the method we've been using, and while this new guidance is still only in draft form, I'll take it as sufficient evidence that our interpretation and application of the guidance is valid and safe.