The experience requirements for licence issue may be gained on any aircraft in the same category, whether or not it holds an EASA CofA. FCL.035 is perfectly clear and unequivocal on this point
Sorry, then perhaps I have the wrong end of the stick. Just to clarify, ar you saying time on any aircraft can be counted for
issue but not for
revalidation by experience, which was the initial issue raised on this thread what seems like several centuries ago. That is what you would logically expect, but logic and EASA rarely if ever sit side by side.