If the requirement for the base of structures be 36″below finish grade. What would it be 5’below finish grade for a walkout well. The walls are retaining boardsoil. A concrete slab will be cast over rigid insulation in the well. How would the frost cover vary, if at all, for thr retaining walls.
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If it's going to be inspected, I'd ask the inspector. Because if we (and you) guess wrong, there will be trouble.
Ask the inspector. Theoretically a retaining wall such as you describe MIGHT not have any vertical loads, but would have a 3 sided box loading your existing foundation wall. Technically, if this is a retrofit, and you dig down and expose an existing footing, you might have to reinforce that footing in some manner, too. Hopefully you have a BO that is not full of himself and is willing to give you a bit of friendly direction. He [should] see this stuff daily, so he should be able to give you some hints on what is acceptable and/or how others have done it.