I would agree with Whopity that the IAA's interpretation is wrong -
but if it is working 'Why rock the boat?'
Previously only Examiners could sign off Revalidations. Which meant that, for Revalidation by Experience, having completed their DUAL requirements with an Instructor, applicants would then have to find an Examiner to complete their paperwork. FCL.945 meant that duly authorised Instructors could now also complete the paperwork at the end of the (last required) DUAL flight.
FCL.945 Obligations for instructors (my underline)
Upon completion of the training flight...
To me, from the above, it is obvious that it is the Instructor who has to complete the training flight (with the SEP Holder) in order to complete the paperwork.
NB: I wish it had been written as
Privilege rather than
Obligations.
Anyone I signed for had done an IR anyway so instructor flight excempt, please explain how the signing instructor would have done a refresher flight that the SEP was excempt from and so hadn't done?
Without having completed the training flight, I do not see how an Instructor is authorised to do this, and an Examiner is required (why not the one who conducted the IR test/check?).
If an Examiner had conducted a SEP Proficiency Check for Revalidation, but had 'forgotten' to complete the paperwork in the candidate's Licence. Another Examiner (
in theory) could sign their SEP Rating. Could an Instructor with 945 Privileges?