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I have never needed to disable business events in all the upgrades I did from 184.108.40.206 to 12.1.3 and I believe it is not mentioned in these docs (I understand it is mentioned in the best practices, but I believe it is not required).
Oracle E-Business Suite Upgrade Guide Release 11i to 12.1.1 [ID 1082375.1]
Oracle E-Business Suite Upgrade Guide, Release 11i to 12.1.3