All GTI/D bumpers have the cutouts with blanks in, but you only get washers if you specify them as part of the winter pack or with xenons.
As for retro fitting xenons, I've fitted W8 bi-xenons to my Passat without washers or auto levellers, in fact no levellers at all, and it has passed 2 MOTs. Generally if your xenons don't look aftermarket, you can get away with them.