This old chestnut again!! I am awaiting a response from CAA on similar subject. First wrote to them 21st September. Then sent again 2nd Oct. Still waiting for a reply!! That's more than 10 days for a response.
I have CPL(H), but the exam credits ran out after more than the allowed 36 months, so did the 7 IR theory exams and then the IR. Now hold a CPL(H)(IR), with multi-eng time and multi-crew but I can't get an answer if I can upgrade to ATPL(H) once I meet the night requirements. I'm not doing the exams again! PS I did 13 CPL(H) exams and 1 resit.
21 exams is enough for anyone I think. It would be nice if the CAA even acknowledged my enquiry.