which then still doesn't meet the requirement for 12hrs PIC in the preceding?
Note FCL.140 gives two options
(2) perform the additional flight time or take-offs and landings, flying dual or solo under the supervision of an instructor, in order to fulfil the requirements in (a).
A Microlight is definately an "aeroplane" however that group has in the past been specifically precluded from European Regulation because many European States have dealt with them seperately, and in some cases, no licence was required at all to fly them.
There is nothing to say that the wording in the NPA is what will appear in the final regulation.
All hours flown on any aircraft registered in an ICAO Contracting State shall count in full towards fulfilling the hourly requirements of this Part as long as the aircraft matches the definition and criteria of the respective Part-FCL aircraft category as well as its class and type ratings.’
A registered aircraft in an ICAO State will not include Permit Aircraft!