Generally, I don't worry about a starter for my standard 10 liter batch. Having said that, it also depends upon the OG of the batch, the age of the yeast, and the type of fermentation profile. I will do a starter for a much higher gravity or if the yeast is greater than 4 or 5 months old (depends upon the specific strain. You can also alter the flavor profile with an overpitch or underpitch. I will slightly underpitch a Hefeweizen yeast. Likewise, I will over-pitch a yeast when I want a slightly cleaner profile from that strain.
I have recently started doing some cell counts on new packages of yeast (mainly Wyeast) to validate my previous data regarding viable cells of older packages. In general, because much depends upon the strain, the packages will be over the 100 billion viable cells if within 4 months of the packaging date. With the recent change to 'best by' date, I decided to check the last couple of packages I purchased to confirm my previous work. Easily the packs were well above the 100 billion cells, even the WY12728 which was packaged in July, 2020 and used in October 2020.