RegAsm? Did I miss something? Up until now we were discussing RegSvr32 to register the COM server.Do you say that it is enough to run regasm.exe on a batch file even without logging in as admin?
By default RegSvr32 will only register the library at system level (DllRegisterServer) which requires admin permissions. However, if your DLL supports user level installation in its DllInstall function, it can be registered with RegSvr32 by passing the appropriate command line switch.
Independently of RegSvr32 (and RegAsm), you can also write the required Registry settings for the DLL using either a .reg file, a batch script or even VBA. This definitely works without admin permissions when just writing to HKCU for the current user.