My opinion is yes, it does, because all useful exposure to the outside world (non-priviledgedprivileged processor mode) would first require a process running in the outside world. That would require a file system, even a temporary, in-RAM, file system.
Another engineer disagrees with me, but I can't seem to prove this beyond all (unknown to me) cases.
Does the answer to this question depend on the definition of 'running'?