The Guidance is an appalling document: Para 2 States:
The Flight Instructors and training organisations authorising the solo flights must be sure that the student pilot has made application to the UK CAA for the issue of the licence.
The simple fact is, if they havent received a licence, they are still a student; if they haven't applied for one they are definately a student.
Para 6 says:
Once the student pilot is in receipt of their licence, unless the licence is a Light Aircraft Pilot Licence (LAPL)
But all licences now include LAPL privileges!
Para 4 states:
All authorised solo flights must be conducted in accordance with relevant legislation and the Approved Training Organisation’s (ATO) approved manuals or the Registered Training Facilities (RF) - Flying Order Book.
RTFs are long gone and never required a FOB neither does a DTO.
It is Guidance not Regulation and very poorly worded guidance!