I agree with having to put thicker screed if you have insulation above the concrete, and in some cases Polypropylene Fibres for reinforcement, however I don't agree with the concrete and then screed being on top of the insulation.
Latent heat is produced when a substance chemically changes state, i.e. when the concrete is setting it produces heat, after set, no heat is produced whatsoever, it will only absorb heat.
Thus any heat produced in the home will travel through the screed and then the concrete until it reaches the thermal barrier of the kingspan, which requires a lot of energy, this is why BCO's and and NHBC are requiring that it be done with the insulation on top of the concrete.
It is always done like this on every site I have worked, even the one I am on now is, its a school with concrete slab floors, thermafloor insulation on top, with underfloor heating, then screed.
On the other hand then yes if its just to be concrete trowel smooth with no screed, it can be laid on the kinsgspan and be the finished floor