GFCI's work on current (Amps), not Volts. Older compressors (refrigerators and window a/c units) pull a lot of amps right when they start. They will trip off an inexpensive GFCI. (Yeah, they are supposed to react to the differential, but they react really quickly.)
If you are building a new house, or renovating one, the NEC is relevant. Where I find issues is where some realtor or home inspector thinks that a house built in 1922 or 1946 should have this or that because they don't understand WHY a GFCI is a good thing to have. (I've seen houses where three or four GFCIs were hooked up in series. And I think rock-paper-scissors was played to decide what to connect where.)
So, a third person just installs whatever someone else said to and creates a problem that did not exist beforehand. There is no safety hazard in having the outlet behind the refrigerator not attached to a GFCI. There is no additional hazard from having the wall outlet in a bedroom (which might be used for a personal a/c unit) not connected to a GFCI.