Are you sure of this? It doesn't require a smart meter for solar panels to export to the grid, so I can't see why it would require one to export battery power to the grid. The key thing is that the export of power can be controlled from an internet-connected grid-tie inverter behind the meter rather than being centrally controlled by the network through a smart meter.
Of course houses with the old simple "spinning wheel" meters need to get new meters as a matter of course when solar panels or controlled load/off peak services are installed, and this would be the case where new battery+solar is installed in a house (but no different that a solar-only installation).
One area where smart meters would be required is implementation of grid-controlled demand management, e.g. enabling the grid to turn down (or off) appliances such as air conditioners or pool pumps during periods of critical demand.
