Just looked that up...
FCL.940.CRI CRI – Revalidation and renewal
(a) For revalidation of a CRI certificate the applicant shall, within the 12 months
preceding the expiry date of the CRI certificate:
(1) conduct at least 10 hours of flight instruction in the role of a CRI. If the
applicant has CRI privileges on both single-engine and multi-engine
aeroplanes, the 10 hours of flight instruction shall be equally divided
between single-engine and multi-engine aeroplanes; or
(2) receive refresher training as a CRI at an ATO; or
(3) pass the assessment of competence in accordance with FCL.935 for multiengine
or single-engine aeroplanes, as relevant.
(b) For at least each alternate revalidation of a CRI certificate, the holder shall have
to comply with the requirement of (a)(3).
(c) Renewal. If the CRI certificate has lapsed, the applicant shall, within a period of 12 months before renewal:
(1) receive refresher training as a CRI at an ATO;
(2) pass the assessment of competence established in FCL.935.
Looks like you're right.
CAA didn't mention this in their recently published guide to new European pilot licencing regulations, which is arguably a significant oversight on their part.
However, it'll maintain standards and credibility of the qualification, which can only be a good thing, even if it does mean a bit more work and money from us.
G