conc slab on top of insulation can be fine for a clean sheet new-build, but on a retrofit where you're digging out an existing concrete slab, you may have challenges getting a SE and BC to sign this off.  We certainly did.   As we were digging down deep  there's a risk of disturbing the existing strip foundations (that were unknown depth/quality until we'd already committed to work, i.e. post BC design sign off),  so all they would approve at the design stage was MOT->slab->insul