For those who are in this position but are unfamiliar with the history, the requirement to re-sit the previously passed theoretical exams if your IR has lapsed by more than 7 years has existed for at least the last 10 years.
LASORS the UK CAA publication detailing licencing requirements has stated in successive updated versions during this time that if you hold an IR on another ICAO licence it fulfills the criteria of having an IR inside 7 years thereby eliminating the requirement *to re-sit the theoretical examinations.
In April 2011 LASORS 2010 was published and without prior warning the CAA removed this condition effectively rendering many license holders unqualified overnight.
There is no other outside legislation driving this decision, JAR-FCL has not changed since 2005, EASA does not come into force until April 2012 at the earliest, this is purely an arbitrary UK CAA action.
Other JAA member states such as France and Germany accept IR's from ICAO licences so the CAA cannot claim to be merely falling into line with other countries.
Aside from the fact that as a responsible regulator the CAA are obliged to give people advance warning of major policy changes such as this, sitting theoretical examinations for a 2nd time serves no practical purpose and offends common sense.
Discrimination also becomes a factor because the CAA cannot point to any differences in standards that would legitimize their sudden refusal to grant an IR without sitting exams having continuously maintained an IR on another ICAO licence.
Neither can they reconcile the contradiction that I'm qualified to fly a HK registered aircraft in UK airspace but not a UK registered aircraft. Remember I'm objecting to re-sitting theoretical exams that had questionable vocational value as a student, not carrying out a CAA IR and skills test.
Having failed to appeal to the CAA's better *judgement I am now pursuing this matter through legal avenues.