One fear EASA must have is that if they give nothing there would be an even greater move to FAA N reg already a thorn in their sides.
Ah I see
But this could easily be solved by limiting it to "not for commercial ops, not for use above FL250". That way *most* N reg or potential N operators who use the rating for private flying (irrespective of what licence they hold) would probably not be N reg. You could say "private privileges only" but that may weed out certain groups who could benefit from an IR(L) like this (FI's spring to mind)....unless worded carefully. Not suggesting that FI's could teach this, just that as example you are an aerobatics FI - the weather may be crap but good enough to climb ontop.......
Cheers...