Bumper is a sharp edge but unlikely to be caught by a passer by so a pass and advise.
The rear wheel arch is the same. Also is it within 30cm of any steering, suspension, brake, seat belt or tow bar mounting point? If it isn't then it will pass. This is because if it is outside of those areas then sect 6.1 of MOT manual asks is it likely to affect the steering or brake of the vehicle in motion and the simple answer in this case is no.
'82 323i henna '90 320iSE sterling silver No more!
'10 116d Sport Red - MkI
'12 1.4 Punto Easy Exotica Red
'11 X3 3.0d SE
'89 240 DL Estate
If the beam pattern and aim is acceptable, and they are not so high a colour temperature as to be considered blue, they will pass. MOT is not constructions and use.
Hey, im a tester and would only fail the wheelarch if it was within 30cm of the suspension turret. By the looks of it i think your safe, the bumper shouldnt be a problem. But if your worried about the sharp edge-passers by thing just stick some tape over it for the test.