Non-inertial reference frames do not abide by the special principle of relativity or global Lorentz covariance. From the article: "energy isn’t conserved in situations where gravity warps the fabric of space-time, since this warping changes the physics in different places and times, nor is it conserved on cosmological scales, where the expansion of space introduces time-dependence". The principle of covariance (see General covariance) in GR implies "local" Lorentz covariance such that the Lie group GL4(R) is a fundamental "external" symmetry of the world. But, the fluctuation theorem has no such requirement and does not imply or require that the distribution of time averaged dissipation be Gaussian. FT (together with the universal causation proposition) gives a generalization of the second law of thermodynamics which includes as a special case, the conventional second law. When combined with the central limit theorem, the FT also implies the Green-Kubo relations for linear transport coefficients, close to equilibrium. Given general covariance along with the differentiable notion of time and space geometry requires linear transport, then its validity would be dependent on the applicability central limit theorem. In addition, the Gallavotti-Cohen fluctuation relation is limited to chaotic dynamical systems
with microscopic reversibility when the fluctuations of a suitably defined function of the phase
space trajectories, taken as a measure of violation of
the detailed balance, i.e. of entropy production, are
measured.