Originally Posted by
FlyingForFun
This is in place of the original EASA text...
That exemption still exists but the quoted guidance from CAP 804 is out of date. The relief for third-country IR holders originated as an exemption applied by the UK CAA near a decade ago under threat of legal action by some ex-pats coming back from Hong Kong (see the thread
UK CAA IR Fiasco). The exemption was approved by the European Commission, under annex V to 2014/69/EU: Commission Decision of 6 February 2014 (available on EUR-Lex
here), but has subsequently become an implementing rule in Part-FCL. The rule exists in the retained EU law because it came into effect before Brexit. The rule, found presently on p 160 of the
UK Aircrew Regulation, is:
FCL.625
(e) Holders of a valid IR on a pilot licence issued by a third country in accordance with Annex 1 to the Chicago Convention shall
be exempted from complying with the requirements in points (c)(1) [, (c)(2)]3 and (d) when renewing the IR privileges
contained in licences issued in accordance with this Annex.
There is a similar exemption for type and class ratings in FCL.740.
Unfortunately the original derogations and subsequent rules do not explicitly say that a third-country IR can preserve the ATPL exam credit for the future issue of an ATPL. That rule nevertheless makes the cut-off point clear: FCL.025(c)(2)(i) "
... 7 years from the last validity date of ... an IR entered in the licence..." For the sake of consistency one would imagine that "
revalidated or renewed in the preceding 7 years" in FCL.625(d) would be interpreted accordingly.