No, I'm using the same thing Pun-Pun does: Broad interpretation of a rule that does not have many limits. Simply, because wish allows access to item creation without prerequisites and GP costs and because item creation is normally limited by those things I can say that it can create whatever I want. I've effectively eliminated all the barriers on item creation that would prevent creation of an item that can do anything through the application of a few rules (Wish item creation, non-xp cost, and custom magic item existence).
Fiat would be if I said that something works without providing a rules example. RAW means that I have provided a rules example.
You might as well say that pun pun creating an ability with the "you gain an ability" wording is imported homebrew. In fact, through my explanation of wish, you could indeed use imported homebrew and remain within the rules as that is what this wish will effectively allow you to do.