In this bug report, it is suggested that D-I does not attempt to sync the clock with NTP if no network was configured....which makes sense...
One way to do this could be presetting clock-setup/ntp to "False" if no network interface is configured in netcfg. So, I hereby propose reassigning this to netcfg. Alternatively, clock-setup could use "some" test (which?) to check whether there is a configured interface (smart use of "ip"?) and then change the default setting of clock-setup/ntp. --
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