Funny enough, but this never crossed my mind before:
In the three-electrode set-up, the working electrode usually is the ground. But in a bipotentiostat, the two working electrodes, say ring and disk, are controlled separately. In that case, I think, the counter electrode must be the ground, otherwise I do not see how the current could be controlled separately to the ring and disk.
As you see, I am not very strong in electronics :)