Looks good.
Has anybody written to the CAA? My experience is that if you send them a precise question, and set out the context so there is no possibility of mis-interpretation, they reply usefully.
A bit of a bombshell, for IMC Rated pilots renting planes from flying schools................... !!
Would also upset not a few syndicates which contains members with the IMCR, but also some VFR-only members. Such syndicates (probably the majority of piston CofA syndicates) tend to gradually fall apart over stuff like this. One I know of, a nice plane too, ended up turning over most of its membership over a nonworking ADF.