The entire 'Leisure Pilot Licence' is an utter crock.
My response to the EASA consultation is that the whole MDM032 proposals should be scrapped. There is utterly no point in a EASA-harmonised sub-ICAO pilot licence; those Member States who wish to have sub-ICAO pilot licences should be free to do so in their own airspace without EASA and its €urocratic intervention.
EASA was supposed to 'deregulate'. It has done nothing of the sort.