Manufacturers of tools with user-replaceable individual cells, could go either way, placing the burden on the owner to use a protected cell, or building in a protection circuit into the tool.
Tools that don't have user-replaceable individual cells, instead integrated into a battery housing, generally use unprotected cells, but with a BMS circuit in series that provides for overdischarge protection, overcharge protection, balance charging, and often thermal protection.
If you gave us a bit more context of why you are asking or a link to a particular tool, it would be easier to determine.