The govenor won't lock out if you increase the pressure to 20, it will only lock if you turn it on too high/fast causing it to
I realise that. Your missing the point. say It locked out because I let to much pressure in to quick when it locked out my gauge was 20milbar the system would still hold the pressure put in as long as there was not a leak.so you would still be testing it.
You would indeed still be testing the pipework, but importantly not all of it. As i am sure has been said a tightness test is required to test from the ecv forward including the annaconda and couplings prior to the regulator.
With the regulator locked out you are only testing from the regulator to the appliances not from the ecv to the appliances so not a proper or full tightness test.