There is always the potential for tolerances to make a particular tire, rim, or combination hard to mount.
A rim being tubeless or not per se does not dictate how hard it is to mount a tire on. Tubeless rims aren't made tighter, i.e. their target diameter for the bead is not a larger number than non-tubeless.
There has always been a cat and mouse game in cycling where no manufacturer of tires or rims wants their parts to be subject to tires blowing off. So sometimes they make decisions that nudge things in the tighter direction; ie smaller bead seat diameter for tires and bigger for rims, and truly difficult mounting situations can result. You can find some tubeless parts that show this phenomenon, but it's not categorical to tubeless. It's probably less common if anything if I had to guess.
In practice, almost all problems people have mounting tires on to tubeless rims relate to them not being deliberate enough in getting the beads sunk in the middle well of the rim. Doing this all the way around is how you make the final tight spot easy. This has to be done on purpose with tubeless rims in a way it didn't so much before.
If you gathered data you might find that tubeless rims had a larger BSD on average and are harder to mount by that definition. Or, you might find that the tighter tolerances are working in both directions, and average BSD is the same. That data doesn't exist. Another definition of which is harder to mount is for which type is it more common to encounter a rim with a BSD that's simply too large and has to be brutally fought to get a tire onto. In my experience that would be non-tubeless, presuming one has good technique with tubeless center wells, as above. I very rarely have that struggle with tubeless rims.
You'll read that Conti road tires err tight and there may be some truth in that, but only to a marginal effect compared to the difficulties you'll encounter if you don't do the above.