Depending on the engine, yes, it might need to be made relatively early. But in practice it's, as everything, design. Some games want to have that element in their gameplay, some do not, it changes things a lot as lighting is used to make things visible (obviously) and to steer attention, it's a fundamental part of level-design, so things change considerably in terms of the game you're playing based on if you want to allow lighting to change or not.
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