You’ve already posted your answer in the topic starting post, but since I am in a good mood I will chew you food for you...
from part-FCL:
When the holder of an ATPL(A) has previously held only an MPL, the privileges of the licence shall be restricted to multi-pilot operations, unless the holder has complied with FCL.405.A(b)(2) and (c) for single-pilot operations.
FCL.405.A
(b) The holder of an MPL may obtain the extra privileges of:
(1) the holder of a PPL(A), provided that the requirements for the PPL(A) specified in Subpart C are met;
(2) a CPL(A), provided that the requirements specified in FCL.325.A are met.
(c) The holder of an MPL shall have the privileges of his/her IR(A) limited to aeroplanes required to be operated with a co-pilot. The privileges of the IR(A) may be extended to single-pilot operations in aeroplanes, provided that the licence holder has completed the training necessary to act as PIC in single-pilot operations exercised solely by reference to instruments and passed the skill test of the IR(A) as a single-pilot.
Regulation (EU) 2018/1974.
FCL.325.A
Before exercising the privileges of a CPL(A), the holder of an MPL shall have completed in aeroplanes:
(a) 70 hours of flight time:
(1) as PIC; or
(2) made up of at least 10 hours as PIC and the additional flight time as PIC under supervision (PICUS).
Of these 70 hours, 20 shall be of VFR cross-country flight time as PIC, or cross-country flight time made up of at least 10 hours as PIC and 10 hours as PICUS. This shall include a VFR cross- country flight of at least 540 km (300 NM) in the course of which full-stop landings at two different aerodromes shall be flown as PIC;
(b) the elements of the CPL(A) modular course as specified in paragraphs 10(a) and 11 of Appendix 3, E to this Part; and
(c) the CPL(A) skill test, in accordance with FCL.320.
So: no, having a hobbyist PPL before obtaining a MPL doesn’t magically grant you the rights to commercial SPO as some kind of loophole in the system which circumnavigates the requirements of FCL.405.A(b)(2) and (c)....which ofcourse a monkey could’ve told you....
Last edited by African_TrouserSnake; 31st Jan 2021 at 19:47.