Yes, in terms of the regulations, he is absolutely correct.Flameport is absolutely correct. I doubt that he would ever reveal whether or not he would feel very slightly slightly happier for an appliance to have an AC RCD on rather than no RCD at all.
However, he is a very intelligent man and,although you may be right that he would never reveal it, I feel sure that, regs aside, he would be (more than "vey slightly slightly") happier with a Type AC RCD than no RCD at all.
If not, the implication would be that he felt that a Type AC RCD offered absolutely no safety benefit over 'no RCD', which would mean that the £billions that have been spent on Type AC RCDs in the UK was all 'wasted money' (and I'm sure that he will have been advocating installation of RCDs at a time when Type AC ones were almost the only option in the UK).
Kind Regards, John