Its was food for though, firstly as we wondered if anyone else was thinking the same thing, and secondly if the policy or applied regulations would consider this a problem area.
The legislation and guide (ED) emphasise the innovation aspects that are central to the assessment, yet the objective test is designed as a pass fail, so surely it wouldn't be considered part 4A tax avoidance to advance via objective measures, or would it?
Lets assume that your pretty innovative, though not confident or well read enough to pass the principals tests, could you scrape up the 100 points you require?
We couldn't comment directly, however one might assume that policy makers would not be concerned with this outcome given the potential for job creation etc.
Perhaps its a little left of field for this early stage company (ESC), though we are curious as to the implications, particularly given regularity or pitches that begin with 'its like Air B&N' or 'Uber & Shopwings combined', not offence intended, though I'm sure you'd agree that innovate enterprises rarely need a 'its like' tacked on the tagline.
Its safe to assume nothing, so we highly recommend you seek professional advice before promoting yourself as an ESIC.