I guess it depends on who approves it? Ive had similar effects drawn in a piece before back when I first posted in this gallery. It did not push my color count above 32 but was still marked as "revisions needed" and I was told I needed to remove the effect.

That is not transparency nor opacity pixels overlayed; can confirm.

Actually downloaded the piece, and it is 38 colors total. It might look like transparency, but actually it is not.
I guess these sunrays are just highlighted colors from the background.

Good job with the mockup, tho.

hmm looks really nice, I like it! Idk if admin will allow it with those sun rays though due to the "no transparency" rule. You can try your luck and see or revise the listing with a render that doesnt have them in it.