The extract from FCL.1000(a)(1) is a broad statement applying to all forms of examining, it could be for a licence issue, or rating issue/revaildation/renewal, or renewal of a FI/FE certificate. The key is the ‘or’.
“hold an equivalent licence
, rating
or certificate to the ones for which they are authorised to conduct skill tests, proficiency checks or assessments of competence and the privilege to instruct for them”
If you are instructing or examining for a CPL licence you must hold a CPL, if you are examining for issue of an ATPL licence you must hold an ATPL. If you are examining for a type
rating you must hold the
rating. If you are examining for an FI certificate you must hold an FI certificate. Common sense really. I think they have misinterpreted and over complicated it.
Try asking the examiner to just put the rating on your CPL instead