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The Changelist notes about the combat Accidents mechanics (Changelist 1.26o (#222)) state it can happen when attacking into terrain with landscape penalties, and attacks into Plains for example should not trigger this.

In this combat log, a Light Armor tank ("Abraham IV") suffers an accident after a RETREAT hit on infantry in Plains.
There were no landscape penalties in combat, and the defender had no entrenchment bonus in this log entry.

save file

Another such case - this time the tank attacks into ruins, but has the Antigrav Lifter unit feat, so no landscape penalties, yet still is killed by the Accident mechanic after a RETREAT hit on an mg infantry.

enemy entrenchment points can still cause accidents to happen. will relook at the hole rule with the militaria feature set though

In the first example, there isn't even defensive entrenchment bonus in the combat log (see screenshot), so really not sure what can trigger the accident mechanic.

rocky plains are actually slightly different from clay and grassy planes and they have some auto-entrenchment value and thus chance for accidents.