It's a very good question; people like to feel they control their armies, and there's little point making a list that few people will play. It should be possible to do so with a little imagination though, for example here's an idea that might achieve the goal and still make an army playable, whille staying true to theme:

Penal Legion 3+ activation
Penal Commissar (20pts) Summary Execution: If a formation fails to activate, you may remove one stand in the formation from play to remove D3 blastmarkers and pass your activation.

In the Insurgency list, there is just more formations; It's OK if a few of them fail to activate, there should be another one nearby.

I've played all of one game with it, but I liked it. It leads to a different kind of thinking.

Like I said, I prefer 3+ rolls to 2+ rolls. A formation with 2+ initiative will let you down relatively often, but with 2+ you're a lot less likely to plan for it. With 3+ you're going to have to have a plan for what you do if you fail - you still get a hold action. You will also probably have more activations to play with, if the points take into account the wasted actions.

I do think Engage actions might need an initiative bonus, as a Hold let's you do at least some of what you tried to do for other actions, but you cannot start an assault with it.

But it's probably not for everyone. Good thing there are a lot of 1+ armies out there for people who don't like failing action tests.

Yeah, for a 3+ army, you'll need LOTS of formations. crush the opponent under a tide of dice sort of thing.

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My shifting projects

Another option is formations that can be expected to perform something reasonably effective on a Hold action. Those kinds of situations allow a player to still exercise control over their forces. It doesn't feel completely unfair. Whether that is a function of the unit abilities, the individual formation or the overall army list org is not terribly important.

Ork formations (especially units with Zzaps and Soopagunz) can reasonably try to Sustain Fire because on a Hold action, the target is still in sight and they still get to shoot. Who hasn't seen a Gargant attempt to Sustain on a 4+ (3+, -1 for BMs)?

Scout formations can use Hold moves to harass with their ZoC.

Failing a Marshall action is bad, but the most important part is usually the Regroup, which can still happen under a Hold action.

In contrast, an artillery formation that fails to activate is pretty much useless. 3+ on them would just suck.

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Another consideration is that you have to watch out for point reductions, lest you create a situation that relies too much on luck. Sure, you could theoretically put a point cost on 3 formations that average 2 activations. However, a run of luck could diverge seriously from those averages.

With 2+ Initiative, 6 activations averages 5 successes. +/- 1 activation is a 20% difference and the max increase possible is +1. With 3+ Initiative, 6 activations averages 4 successes. +/- 1 activation is 25% difference and you can get up +2 for a +50% boost.

A substantial point drop based on the average, combined with a couple lucky rolls that blow the curve could be a big deal.

I would go further in suggesting that this is the reason why it seems like the majority of lists are 1+ to activate rather than 2+. It is an inherent trait that people *want* their troops to behave as ordered, whereas in reality that is often far from the truth.
IMHO having so many 1+ activation lists is actually the underlying reason why there are virtually no 3+ activation lists; it would put them at a significant disadvantage. If such lists were produced, they would need to have some special characteristic (stolid under fire?) that ignores BMs to avoid reducing the activations even further.