I am a trained electrician and would have preferred to simply nail them down with OBO dowels, but our engineer advised against doing that. If the bitumen membrane is not damaged, there is no need to worry about whether it is permitted or harmful.
We then glued the pipes (including water pipes and supply/return for the heating control valve) to the bitumen membranes using strips of bitumen membrane. It was a lot of work, but it went quite well.
I would do it that way again.