Sorry, but the other leg of the circuit is the positive to the battery, so even a component (ECM, BCM, ...) connected to chassis ground will be isolated in the sense there is not a complete circuit through the battery.
The purpose of disconnecting the battery is to isolate the sensitive components from the electrical surges that seek to complete their path to neutral potential through a component, back through the battery positive and battery negative; not to protect the battery.
Every required step in a service procedure contributes to the labor operation code and time paid for that code. The manufactures do not pay for unnecessary steps. In fact, there is a reward (Suggestion Program) for reducing any unnecessary steps/procedures in labor operation codes.
What reason do you propose the manufactures have for requiring battery disconnect?