I can't recall ever having seen a flat circlip on a motorcycle piston. I've put a few in in my time and in a variety of bikes and they have all been wire ones. I'll admit others may have done more but I'd number a tomos moped, a minsk 125, a Jawa 350, an assortment of Honda 125 singles and twins, C90, RD350, GPZ500, GPz305, T500, and of course the bullets.
I always bend the old ones over backwards between two pairs of pliers when I take them out so I don't find it lying on the bench later and worry about having potentially missed one out.