I have had a lengthy call with the CAA this morning regarding who adopted what on the 8th April and they have absolutely no idea!! There is no EASA list saying who has adopted Part FCL and who has applied for derogations. They have told me that they understand the vast majority of member states have adopted with effect from the 8th without derogation but are awaiting confirmation.
The ones that seem to have adopted Part FCL immediately seem to be those that struggled with mutual recognition audits in the past as there is no concept of mutual recognition. If you issue a Part FCL licence or state as the UK did that your JAA licence is a Part FCL licence then it has to be accepted.
It would seem that the derogation to give a transition period for the dual licensing was to low down on the list. Speaking to the Spanish DGAC as well today, as far as they are concerned they have no plans to apply for a derogation at this time so expect N Reg pilots to be compliant.
I have dropped mails to the other NAA's that I deal with at work to ask opinion.
But it does strike me that this has become somewhat of a beggars muddle..