Hi trommel
Don't confuse JAR-OPS and JAR-FCL. JAR-OPS address operators only. They don't give any provisions for the validity of flight crew licences.
Revalidations of IR(A) are covered by JAR-FCL 1.185 (a), 1.246 (a), as you already know. However, it appears to me that you might not have read JAR-FCL 1.246 (a) thoroughly enough. Note that there are different cases.
- The revalidation of the IR can be combined with the proficiency check for revalidation of a TR/CR or not. When both are combined JAR-FCL 1.246 (a) (1) is applicable, or else JAR-FCL 1.246 (a) (2) is applicable.
- In the former case there is a difference between multi-pilot aeroplanes and single-pilot aeroplanes. For single-pilot aeroplanes JAR-FCL 1.246 (a) (1) refers to Appendix 3 to JAR-FCL 1.240; for multi-pilot ones it refers to Appendix 1 and 2.
Hopefully, this will point you in the right direction.
Best regards
hvogt