I was stupid and listened to my plumber...he just said it's easier to wind a boiler down than realise it's too small. If there were models between 28Kw and 38Kw we would have had a bit more discussion. Also at the time it was my first new boiler and I just went on blind faith.
A few other plumbers since then have told me that it wasn't a bad choice as a 438 has a bigger and better heat exchanger so works better than a 428, even with the 438 wound down to 28Kw.