Unfortunately, it does indeed.
I was furious with the CAA at the time, because they hadn't consulted with anyone in industry. Someone there tried to allege that the reason was "Because they don't do limited panel UPs on MPA IR revalidations, it isn't sufficient". When I pointed out that there was no requirement whatsoever for UK ATPL holders to do anything to maintain their perpetual IMC Rating privileges, it was clear that the Belgranist hadn't thought of that.....
I was going to take the cudgels up further, but a colleague who is a ba captain went and failed an IMC revalidation flight test - hadn't flown an NDB approach with a DI for years...... So that rather took my ammunition away.