I've just gone back to the team for further clarification and the way it stands is this.
My apologies to Bungle, Ishould have said that the front panel can be included in the flip front.
The inner wing should remain structurally sound as it serves the same purpose as the stay bar but is the ORIGINAL OEM and any holes MAY become an issue due to the structure being considered borderline on strenth by VOSA with the front flipping .
So, provided the inner wings are kept intact and un-modified, a flip front should not be classed as a monocoque mod.
Thanks for you continued help and interaction in this 1960Zody - hopefully it will provide educational to both Mini owners AND the DVLA.
Unfortunately their last response to you shows they do not know the vehicle in question well enough and are clutching at straws. The inner wing does NOT serve the same purpose as a brace bar as it is not connected to the subframe. Once the front panel and outer wings are made into a flip front the inner wing does nothing and is connected to nothing.
(In fact there is an arguement that even the brace bars are a superficial requirement and do not provide any support to the front of the subframe - but that is a discussion for another day!)