If you use m12 bolts and dock washers above the plywood to distribute the load it shouldn't be an issue. The plywood is the weak part. A bolt with a regular washer could pull through if there was an accident, but highly unlikely in general normal use. With a dock washer it'll likely stay attached in an accident. Dock washers are just large diameter heavy washers. You could make your own from a short piece of strap iron, and just drill a clearance hole in the middle. I'd use 1.5" wide 1/4" thick mild steel strap iron, or anything with a net higher tensile strength. You could use a carriage bolt on the strap iron, and then have the nut below. That will give you a wide flatter top surface to the fastener. Use low strength thread locking compound to keep the nut from loosening, and to prevent corrosion in the threads.
Another option would be to use elevator bolts. They have a large diameter head, and would present a relatively smooth surface inside. Elevator bolts at McMaster-Carr:
http://www.mcmaster.com/#elevator-bolts/=lgwlrl These are only standard grade strength. I've never seen elevator bolts in higher strength grades. Looks like they only have up to 10mm. I'd maybe go for two or three at each corner. You could put one where the frame's hole is, and another three inches away along the side.