Final Score: CAA 1: PeeToo 0,
For reference this is what they said:
Thank you for your email.
Prior to the introduction of EASA Part FCL in 2012, individual training schools gave privileges to instructors to provide CPL Training. When pilots submitted their applications to convert to an EASA licence with us, there was a box on the application form for pilots to annotate the Flight instructor privileges they held. If a pilot had annotated they had CPL instructing privileges, we would have then asked them to provide the evidence from the training provider. This would then have been completed as part of the conversion process. I have reviewed your conversion application and confirm that you did not tick the CPL instruction privilege box.
We would therefore have presumed that you did not hold these privileges. To enable us to endorse CPL instructing privileges now, you would need to submit an application for a variation of your instructor rating, using the online application form, within the attached webpage and selecting the variation option
Online applications for instructor privileges | Civil Aviation Authority (caa.co.uk). We will also require logbook evidence that you have 200 hours of flight instruction in the category or written confirmation for your previous training school that they had given you CPL instructing privileges. Please accept my apologies if this was not fully clarified in our previous emails.
Kind Regards
X Technical LeadFlight Crew Licensing
So basically, whether you apply for the (e)privileges at the time your FI rating is being renewed, or not, you will still have to pay £96 for it, unless you were previously on record as having been a CPL instructor under the old system