Engineered directly onto 20mm insulation board?

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Hello

Solid concrete floor with pine parquet blocks (20mm thick) at present. I am considering ripping them up and putting engineered oak down.

The solid concrete floor has no insulation.

Can the 15mm engineered planks be placed directly onto 20mm kingspan or similar board, or would i be better off leaving the parquet blocks down and placing the boards over that?

Concerned about sagging over time of the insulation board. I have about 38mm to play with, so not enough room to have chipboard or MDF over the insulation board unfortunately:

DPM - 20mm (MDF or insulation, or existing parquet) - underlay - 15mm engineered

Thanks
Mike
 
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In case it helps anyone else, celotex said no - must be a minimum of 22m chipboard on top of the insulation.
 

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