ruserious,
you've got me reaching for my FOM (wherever it is)! They can count days off down route for the purposes of the 7 then 1 off, 2 off in 14 rules, but not for min days off per month. These must be spent in Dubai. It's all in chap 21, but have to admit I haven't checked recently.
I notice that scheduling seem to have dropped all responsibility for monitoring this type of compliance (clearly out of necessity). We're on our own.
Oh, and my average days off are 9-10.