What is quite clear from the latest NPA is that in order to obtain "grandfather rights" the holder of the rating will have to meet the JAA IR standard
It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges.
A high uniform level of safety is ensured by requiring the applicants to pass exactly the same skill test as established already for the IR in Part-FCL.
As IMC rated pilots are not trained to the IR standard, very few will achieve any grandfather rights without spending a considerable amount of money. The Test will be conducted by an IRE, who charge twice as much as existing PPL FEs, and be twice as frequent (12 as opposed to 25 months), resulting in a price hype by a factor of 4 to begin with.