There is no difference in the approval fees charged for an ATO as opposed to an FTO. For the modular IR, the proposed initial approval fee for 2012/2013 is £1294 per module (BIFM & PIFM) with an extra £647 if the course is to include synthetic flight training. The current fee for initial approval of the 'old' modular IR course is £1269 (+£634 for the addition of synthetic flight training) so splitting the course into 2 modules appears to result in the initial approval fee more than doubling. This does not, of course, include the fee for qualifying the FSTD (£7431 for initial qualification of an FNPT II).
Proposed annual re-approval fees are £1156 per module and £1676 for renewal of the FNPT II qualification.
Doesn't that mean, in effect, that no ATO is going to bother to do IR training unless they do it already?
I did wonder about the sim approval costs. They are big, but hard to avoid since most customers are not aircraft owners and sim time is thus cheaper than flying.
One could argue that private owner-pilots may generate new revenue and I would guess most of the SE owners would choose not to use a sim (as I have done) but I don't see this as a vast new market. Especially with the 2014 derogation on FAA to EASA IR conversions, which may be extended again as necessary.