Checking the exact first line is far too strict. It should be in the first few lines, although most scanning tools do not actually care.
Common examples put file identification and copyright info ahead of the SPDX comment.
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Created a GitHub issue: Revise SPDX check to first 25 lines · Issue #316 · bemanproject/beman-tidy · GitHub
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This is addressed in beman-tidy 0.5.0.