I think you are being a bit too strict (coming from a trader that has a Darwin with a D-score of 59.5 )
An alternative would be to allow the Darwin to be created (so the trader can monitor performance) but prevent outside investment. Maybe allow Darwinia qualification to keep interest.
When I stopped trading ILR, I invented the following requirements for my new trading account:
First step before creating a Darwin:
Make 100% profit on the trading account or a D-Score of at least 40.
Second step: reach the other requirement.
Third step: show 4 consecutive months with significant profit.
Fourth step:: make 50% on your investment in your own Darwin.
Fifth step: make a D-Score of 55.
Now you're ready to create a public Darwin.
Unfortunately Step 4 is not possible without creating the Darwin before.