I’ve had printers that were rock solid, and I created a mesh, and I got perfect first layers every time with just a quick Z probe in the centre of the bed. Other printers have been a little more problematic, and I’ve run a full 9 or 16 point level before every print (I start with 9, and just keep increasing the number of points until I get the results I need). I would usually add the commands to the start code for that printer in the slicer, that way I don’t have to remember which printers need it and which don’t - the printer just heats up, then levels, then prints.
For Delta printers I always run a Delta auto calibration before each print, and means that if one of the towers is out of alignment, I won’t matter.
In the end though, there isn’t a hard and fast rule - you do what you need to do to get a good print on the printer you are using. In the scheme of a 40-hour print, the two minutes it takes to run full bed levelling hardly seems like a big deal right? It probably takes longer for your bed to heat up…