The Commission Regulation (EU) 2015/445 FCL.1005 '25%' rule change was discussed at EASA's #5 FCL TAG/SSCC meeting at Köin in June 2015. I stated:
The word 'required' is ambiguous. Does this mean the mandatory flight instruction (e.g. 25 hours for the PPL) or the actual flight instruction the applicant needed ('required') to meet the standard to be ready for the Skill Test? For example, if he/she had needed 40 hours of dual flight instruction, would the '25%' figure mean 6.25 or 10 hours? We assume that it means 6.25, but this ambiguity should be resolved.
After discussions, the conclusion was:
Outcome: The participants agreed that the 25% rule should at this moment be based on the minimum hours established in the ATO course approval. However, this issue should be reviewed by the GA task on simplifying the balloon requirements to further clarify the intent. This task is already considering changing the 25% requirement to 50%.
The issue was subsequently reviewed, but no changes have been made. The UK CAA has also adopted the outcome policy stated above.