(Not sure whether there’s room under there when the OpenPGP card slot is already in that vicinity but)
Technically, no, because if plugged into a power source (via USB-C), the phone is powered even without a battery. Sure, that raises the required level of user error.
I’m not an electrical engineer but … I would like to think it is possible to engineer a SIM card or SIM card interface where the SIM card doesn’t get nuked if you eject it while powered. Isn’t that the direct approach to fixing this problem?
I guess the other (future) approach is to replace the SIM with an eSIM. Then there’s nothing to eject, as well as simplifying the hardware layout, as well as more readily admitting the possibility of having a dual-SIM phone.
Better add the “app store” app to that list of inclusions.