I think many are requiring it now. I remember people saying here that KESC requires it, a friend got solar installed in Fsd and as per FESCO, they require 3-phase inverters as well for net-metering.
Reason given be that there are lots of transformer blow-outs because of 1-Phase net-metering - which I suspect is due to unbalanced loads i.e. lots of energy being sent to transformer over a single phase. So the correct solution should have been to divide 1P net-metering customers to different phases and tell them to keep their inverter bound to specific phase. But as is the case in Pakistan, they just pass a blanket requirement, making life difficult for everyone.