bpilatus
Unfortunately the ANO does not use the word should.
With regards evidence, the FAA IR does not require renewal as long as you are able to self certify currency.
I know some don’t like the comparison between us and the States. However the fact remains there are hugely more private pilots in the States flying in all sorts of conditions. You mention evidence - well look at the evidence from the States regarding the use of the IR by private pilots and also consider the accident statistics. For me it is a pretty persuasive model that their system works - and works very well.
In Europe there a a significant number of pilots operating N reg. I cant remember the last time I saw an N reg accident here in IMC conditions. Moreover I also cant remember a significant number of accidents involving pilots with an IMCR in IMC.
DFC writes about the IMCR not being with us much longer. Perhas it will not be but I wonder if anyone will bother to do a regulatory impact anaylsis if the rating is withdrawn and if they do I wonder whether anyone will consider what the safety implications are?