UA correct me if Im wrong.
I think UA is saying something along the lines of:
Done the ATPL theory then the CPL
ATPL theory expires
Redo IR theory exams then do the IR
therefore you have a CPL/IR but it is not the ATPL(f) so to speak as your ATPL theory had expired before you did the IR.
This is where the JAR system becomes very grey in reasoning. I wander if the IR review will take this area into account.
mint