There are still loads of people with IR issued after the 24/4/18 floating around without PBN because of the lack of PBN approaches/aircraft and simulators. I have done 5 IR revalidation in the last week and added PBN as part of the test. I do all initial IR tests with a second part of the test in our PBN approved simulator as standard and we are "sweeping up" the renewal and revalidation's as the come through the door.