If your personal view is that it is OK to issue codes on the basis of 'non-requirement' things in Appendices of the regs, how far do you think that concept should be taken? Would you, for example, also expect 'codes' to be issued for 'non-compliance' with the OSG, some bits of which seem a little odd to some of us?
I see no reason to go further than the main text.
Foreword Any reference in this text to... the Regulations(s)... shall be taken to refer to BS 7671:2008 Requirements for Electrical Installations.
634.2Any damage, deterioration, defects dangerous conditions and non-compliance with the requirements of the Regulations, which may give rise to danger, together with any significant limitations of the inspection and testing, including their reasons, shall be recorded.