Headlamp washing and levelling systems are a legal requirement and required if the LED headlamp or high intensity discharge lamp has a luminous intensity exceeding 2,000 lumens.You think they won’t pass an MOT strictly speaking? What’s your thoughts or reasoning on this?
If the luminous intensity isn’t marked on the lamp, a tester won’t be able to tell if these systems are needed. In this case, the headlamps will be treated as ordinary lamps and the vehicle can be passed as they don’t need washers or levelling devices fitted.
From Gov.com

Customer service centre commonly asked questions – Matters of Testing
Official advice and information about MOT testing from the Driver and Vehicle Standards Agency (DVSA).
I didn't know about the second paragraph above, so maybe there's no issue after all.