gipsymagpie I cannot see "sole manipulator" in the ANO but that is, in any case, not relevant.
The ANO passes the buck to EASA (see below
my italics), so one does need to know, and follow, what the EASA rules are.
Requirement for appropriate licence to act as member of flight crew of EASA aircraft
registered in the United Kingdom
136.—(1) Subject to paragraph (2), a person must not act as a pilot of an EASA aircraft that is
registered in the United Kingdom—
(a) without holding an appropriate licence granted, converted or rendered valid under the
EASA Aircrew Regulation;
For a Licence to be valid for CAT, or Passenger carrying, EASA only require that the 3 x T/Offs, Approaches and Landings in the previous 90 Days are "Carried Out" in the relevant Type, or Class, of aircraft.