Ahh, bless. Well excuse (1) is wrong because the 7 year validity becomes live for CPL IR holders on passing their IR and allows them to upgrade to ATPL without taking the ATPL exams again and (2) this is an EU regulation, not in their discretion, so they really should comply. Let's see what Austro say. One often gets answers 'shot from the hip' without proper consideration. Of course this question has only arisen since exit day.