The confusion with CPL requirements is that there are at least 5 different hours requirements!
Three of these relate to various different types of integrated courses, so we can ignore them.
The two which apply to modular courses are:
- Before commencing the course, you must have 150 hours total time. The night rating is not required, but if you don't have one then the CPL course must include at least 5 hours of night flying in addition to all the normal requirements
- Before applying for the license (i.e. after you complete the course and pass the test) you must have 200 hours total time. This must include 100 hours P1, 20 hours cross country, and one cross country of at least 300nm two full-stop landings at airfields other than the airfield of depature.
So, the answer to your question is that you do not need 100 hours P1 prior to starting the course. But, since you won't log any P1 time on the course, if you don't have 100 hours before you start the course then you will need to build these hours after completing the course before you can apply for the license.
The 70 hours P1 requirement which LFS has mentioned is not, technically, anything to do with the CPL. It's a requirement for a multi-engine class rating.
FFF
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