No rocket, Keygrip. Detail and accuracy are essential when dealing with JARs for the very reason that they are only Requirements and not Regulations. It is when this required accuracy is dismissed as pedanticism, with the implication that it is no more than unnecessary nit-picking that the missiles start flying.
The fact is that individual countries can only implement the Joint Aviation Requirements so far as existing national legislation allows, in this case the Spanish Authority clearly has a problem implementing the requirement for 100hrs PIC for issue of the licence, although whether this is a matter of Spanish law or the competence of the civil servant(s) involved is debateable. It is the same conflict that resulted in the UK CAA approving training outside the JAA, contrary to the requirements of JAR-FCL - UK legal opinion was that to implement the Requirement would have been contrary the provisions of the UK's Aviation Act that bound the UK CAA to approve any organisation that met the stated requirements, wherever it was based. As Keygrip doubtless knows, JAR-FCL still limits overseas training to all or part of the integrated ATPL course, which requirement the UK is still legally bound to ignore (for another year or two, at least).
The panacea to this confusion is, of course, EASA, which will enshrine large parts of JAR-FCL in European law, consequently making it binding on all EU member states. That, at least, is the theory, although history suggests that the whole thing will become mired in the corruption and dishonesty that epitomises the EU and will be routinely ignored by many states, principally, on past form, France, Italy and Spain. It does not bode well that the UK's opinion was largely (totally) ignored during the consultation process. Having eventually found the Comment and Response documentation on the EASA website, (it was in a locked filing cabinet in the basement under a sign that said 'Beware of the Tiger') close study revealed that the UK CAA was not mentioned once as having presented a response to any of the questions raised. The implication is that licensing under EASA will be stitched up by 'old Europe' to its own advantage and the galloping protectionism evidenced by the recent 'bra wars' debacle will be the inevitable result.
Keygrip is quite correct in his observation that accuracy and detail are important when presenting a question on PPRuNe. In a clear majority of cases, questions presented on this forum are all but unanswerable as there are so many possibilities dependant upon experience, qualifications, State of Licence Issue, future intentions, etc. All that the well-intentioned respondent can do is to present the facts from JAR-FCL and hope for the best. However, this is made no easier, as willby points out, when the UK CAA ignores the clearly stated requirements of JAR-FCL for no good reason and publishes blatantly incorrect information in its own document. LASORS - The Definitive Guide? - Horse droppings!
In the absence of any other information, advice and responses to questions on this forum tend to be based on the UK's interpretation of the Requirements on the assumption that most of the questions come from UK-issued licence holders or from others seeking a UK-issued licence. This may be frustrating to those who do not have the UK as the State of Licence Issue but understandable when one considers that the UK approves more training organisations under JAR-FCL than all other member states put together.