The danger with that is that it will deflect from getting a more easely achievable instrument rating for the PPL as EASA will make a empty gesture tell us that we now have an IMCR and then forget an achievable European PPL IR.
In my mind the best route forward would be for a modular IR ie a junior version for below RVSM airspace with maybe allowances for experienced pilots to apply for a pre test test. If that is passed then you can take the full examiner IR flight test.
On the exam side a cut down version more designed towards the PPL and able to be completed in a full time 2-3 week course.
Pace,
This is still WAY WAY WAY over the top, and shows typical "European thinking".
Whay have a "pre test test"? Just go for the test and if you fail then you require remedial training and another test.
Why have a "3 week course" for the exams? Nothing is rocket science and I self studied for the FAA IR and FAA CFII exams from the Jeppesen Instrument Commercial manual. No big deal.
UNLESS the EIR has: A precision approach, the ability to self study for the exam, allowances made for previous time and qualifications, the ability to train at your local flying club then it is a non starter and a waste of time. You'll just get previous IMCR holders / Foreign IR holders flying illegally "vfr".
If the aim is to encourage new pilots to get an Instrument qualification then the "course" needs to be as easy, cheap and least hassle as possible.
What really needs to happen is to have this EIR, with a precision approach capability, which can then be upgraded later on.