Yes and another point that renders the original scenario moot for operators under EU-OPS. But still not a general prohibition under ICAO.
Is EU-OPS a thing anymore? Our manuals are EASA-IR...
99.9% of EASA Operators comply with CDFA approaches regulations, therefore You can't level off and wait for the Mapt whilst being levelled.
I fly for an EASA operator and we most definitely can level off and fly to the MAPt
*on an instrument approach planning to circle-to-land*.