I actually got a reply to this question from the CAA.
The amendment to the Aircrew Regulations that implemented the Basic Instrument Rating was included in the regulations that were incorporated in to UK domestic law when the UK left the European Union. Therefore it is now up to the CAA to decide whether or not to implement the BIR. A review to decide the matter is ongoing but unlikely to be complete by the time EASA implements the BIR in September.
The BIR would be of limited value unless a mutual agreement is made to allow a UK BIR to be used in EASA airspace and an EASA BIR to be used in UK airspace. Nobody knows if an agreement could be made notwithstanding that article 445 of the Trade and Cooperation Agreement provides for such cooperation.
In any event, I think the BIR is not a replacement for the IMC rating. The BIR significantly more demanding than the IMCR. I think therefore the IMCR should be retained as an entry level IFR qualification.
Given the precedent of the BIR, I would like to see the option of a competency based IMCR. Where the IMCR is done at a DTO there would be no change. However where the IMCR is done at an ATO approved for CB-IR or BIR, the regulatory requirement for 15 hours flight training should be removed. Instead it would be for the ATO to determine the training required to achieve competency. In practice this would enable an ATO to decide on the most effective use of FSTD, other training devices and aircraft to meet the training objectives and the needs of individual students.
Last edited by Rivet gun; 21st May 2021 at 08:11.