DALI DAPC OFF command
Yes that will be a compliance fail. The LED must go completely off when requested, so you must configure the circuit so that this occurs.

Also DAPC 0 is not the OFF Command,  they are two different commands, although they must both result in the light output going to zero. DAPC 0 will fade to off using the current Fade Time setting, such that the transition to off occurs at the end of the fade time. Direct Arc Power commands have bit 8 in the 16 bit frame clear, all other commands have it set.

The Off Command is an immediate off with no fade. Bit 8 in the 16 bit frame is set, bits 7-0 are the opcode and are 0.