It is part of the EICR to say that an SPD is not fitted when it should be. Section 443 of BS7671:2018 gives very specific details of when it is or is not required. If it should be fitted and is not it is is a non-compliance and must be noted. Is it dangerous? Unlikely. Could it be better? Yes. C3 improvement recommended.
And 443.4 contains an exception for single dwelling units "where the total value of the installation and equipment therein does not justify such protection"
Which is surely a judgement call to be made by the person occupying or owning the dwelling. It is certainly NOT the place of the electrician carrying out an EICR to make that call.
As a homeowner, my judgment is that the chance of any damage being caused by a TOV in my locality is so low as to make the fitting of an SPD unjustified.