Without all the nuances of the above posts in front of me on one page, let me just say that:
1. I raised with EASA over 18 months ago, when FCL was being drafted, the issue of hours on non-EASA CofA aircraft in the relevant category - i.e. aeroplanes, gliders, balloons, helicopters - counting towards maintenance of an EU licence (i.e. 'currency' which also includes medical compliance periodically)
2. I was assured by one of the leading EASA rulemakers that the intent was that hours on non-EASA CoA aircraft would count towards the periodic requirements to maintain an EU licence. BTW it has been confirmed that EU licences are 'for life' subject to maintaining the required experience, medical and periodic 'flight with an instructor' whatever. So no renewals per se.
3. I was also told that the wording in the implementing rules in respect of this maintaining currency issue would not be specific, so as to allow NAAs to adopt the widest interpretation; this rather than trying to specify which categories / groups / classes whatever of aircraft not subject to EASA airworthiness control would be acceptable for maintaining the EU licence.
The legal texts are not easy to get one's head around - classic lawyers' drafting of double negatives, lots of parentheses etc. So, next week when I meet with the Rulemaking Director for the regular six monthly 'chat' this subject will again be on my agenda. Before I do I shall re-read the EASA Opinion on FCL, which was adopted by the Commission's EASA 'comitology' Committee on 8th December, but with some amendments which are not yet published as the final text and which may still be subject to any changes the EU Parliament may want to introduce if prompted to do so. This is the latest stage of FCL becoming EU law, and is well past the (public) comment response stage of last year.
BTW, for those who may not appreciate it, Cliff Whittaker, CAA, is very much 'onside' with our needs. He may, however, and quite understandably have not quite got this topic right.
DGR / President, Europe Air Sports