Well done, foxmoth - you couldn't have got it more wrong!
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JAR–FCL 1.355 FI(A) – Revalidation and renewal
(See Appendices 1 and 2 to JAR–FCL 1.330 & 1.345)
(See IEM FCL 1.355)
(a) For revalidation of a FI(A) rating the holder shall fulfil two of the following three requirements:
(1) completed at least 100 hours of flight instruction during the period of validity of the rating, including at least 30 hours of flight instruction within the 12 months preceding the expiry date of the FI rating, 10 hours of this 30 hours shall be instruction for an IR if the privileges to instruct for IR are to be revalidated;
(2) attended a FI refresher seminar, as approved by the Authority, within the 12 months preceding the expiry date of the FI rating;
(3) passed, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR–FCL 1.330 and 1.345 within the 12 months preceding the expiry date of the FI rating.
(b) If the rating has lapsed, the applicant shall meet the requirements as set out in (a)(2) and (a)(3) above within the last 12 months before renewal .
JAR–FCL 1.315 Instructor ratings – Period of validity
All instructor ratings are valid for a period of three years.
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If an FI has not achieved 100 hours instructing in 3 years (not 25 months) then it is, in my view, quite right to require him/her to attend a seminar and undertake a proficiency check to confirm that he/she has not become too rusty.
Strangely enough, there are a few FIs around who instruct so little and have such a tenuous grasp of the regulations of their trade that the seminar/proficiency check is a very good option.