For my floor, I welded wood screws upright on the steel floor, then screwed 2" pieces of dowel (1.25" diameter) through holes in the 2" XPS foam board and onto these screws; I then screwed 3/4" plywood to the dowels on top. This gives my plywood flooring a solid mechanical connection to the steel floor and lets me secure furniture and cabinetry to it with no problem, and without putting any new holes in the steel floor.
This basically evolved out of my original plan to do something like what you're suggesting, with 2X "joists" bolted to the steel floor. I went from there to welding angle brackets on the floor that I could screw the 2X4s to sideways, then to welding just the screws and spinning down small blocks onto them. This would have involved cutting lots of very accurate small square holes in the foam board to fit down onto them, and I eventually realized that dowel could be spun down after the holes were cut so no elaborate measuring would be required (the spots for each hole can be marked by just pressing the foam board down over the welded screws).