https://iaeimagazine.org/magazine/features/ungrounded-electrical-systems-ungrounded-photovoltaic-pv-systems-what-is-the-world-coming-to/ said:
In utility-interactive PV systems, the inverter can be greatly simplified to a conceptual switching device and a filter with other added control components. Of course, how the utility-interactive inverter actually works is far more complex. The switch reverses the polarity of the dc output from the PV array 120 times per second to generate a 60 Hz waveform that is shaped into a sine wave by the filter. In Europe, they use 100 switches per second to get 50 Hz. Because the European PV arrays and the electrical system are ungrounded, the PV utility-interactive inverter can be relatively simple compared to what is required in the United States. In the U. S., with a grounded circuit conductor from the PV array and a grounded circuit conductor in the ac inverter output circuit, it is not possible to use a direct switching device because the switch would be shorted as it tried to reverse the polarity of the dc circuit into an ac signal. A transformer is required in inverters used in the U. S. to isolate the grounded dc circuits from the grounded ac circuits. The transformer is usually a heavy, costly, and bulky device that decreases efficiency, increases the size, and increases the shipping costs of the inverter.
U. S. inverter manufacturers and inverter manufacturers in the rest of the world can now sell transformerless inverters in the U. S. Those inverters must be used with an ungrounded PV array, and theNECallows such ungrounded PV arrays (see 690.35).