it would only be a problem if there were no additional 10kb limit. the 10kb limit can't be overcome.

the only reason to forbid the ; tricks (they are no cheats!) is readability but if the sources are a mere 10kb it won't be hard at all to deobfuscate the code if you are interested in how it works.

in my opinion there should have been only the 10kb limit right from the beginning. that's a clear and simple rule without room for misunderstandings. with "100 commands" you can't achieve that. what is a command? will they be counted in the produced assembler/machine code? does it mean a7 function calls only? (you could again do tricks like inlining all vector calculations and so on...)