The derogation for non-commercial operation by third country licence holders is already written into the Regulation (Article 12, para 4).
The so called '15 hr IR conversion route' is unlikely to be affected in practice - the actual requirement at present is that training is at the discretion of the FTO but may not be less than 15 hours. Whilst Article 8 of the Regulation suggests that the competent authority should itself determine the credit to be awarded to each applicant, based upon a recommendation from an ATO, the decision is, in fact, likely to be delegated entirely to the ATO provided that a certain minimum training time is observed (e.g. 15 hours).