Does the Australian "IMCR" not have an SRA as the basic module privilege?
I believe that the proposed "enroute IMCR" would be fine if its first module had an SRA. Otherwise, it doesn't add up to me because in any case where the destination is not VFR (but was forecast such otherwise the flight would have been scrapped) the pilot will have to declare a mayday - but he will not have the skills to fly any IAP. The mayday will legalise the situation but the pilot is likely to get killed if he cannot get down without losing control or whatever.
I think of this stuff in terms of what I would teach someone as the absolutely basic requirement if I cared for them. It would be a "PPL" with an ILS. But I think that is just too radical in this case in which politics is 90%.