The regs say it is. After all, the power cut could be caused by the cable being cut just outside your house, which would cut the earth as well. Or even the cable being deliberately removed (to replace it, for example).
The setup I described had one circuit fed from the generator not passing through the CU. In this case you would need another RCD (or RCBO). If the generator supply passes through the CU RCD, then you don't need to add another one. But you do need RCD protection on every circuit, as your generator is TT earthing - if your CU only has RCDs on some circuits, you either need to add more RCDs/RCBOs or put a time delay RCD in front of it.
Yes, that's the downside of putting everything behind the changeover switch - you can't see when the power comes back.
Mike