"need not commence or may discontinue the instrument approach procedure when:"
b. ByNight.AtanaltitudenotbelowtheLSALT/MSAfortheroute segment, the appropriate step of the DME or GPS Arrival Pro- cedure, or the MDA for the procedure being flown, the aircraft is established:
(1) clear of cloud;
(2) in sight of ground or water;
(3) with a flight visibility not less than 5,000M; and
(4) within the circling area or VAA - H, as applicable; or
(5) within 5NM (7NM for a runway equipped with an ILS) of
that aerodrome aligned with the runway centreline and established not below “on slope” on the T-VASIS or PAPI; or
(6) within 10NM (14NM for Runways 16L and 34L at Sydney) of that aerodrome, established not below the ILS glide path with less than full scale azimuth deflection.
Note: Reference to circling area in this section includes the circling area for the category of aircraft or a higher category where the limi- tations of the higher category are complied with.
So, if you are still using DGA steps, or in your example an RNAV with no PAPI, to descend, then you may not discontinue the approach until established in the circling area, so the speeds still apply.
If it were an ILS, however, and within the distance limitations, you can start the visual approach not below glide slope and as you have not commenced or have discontinued the speed restrictions do not apply.
Another example I can think of would be where approach may descend you by dme steps without actually giving you the approach. In this case you have never commenced any approach until hitting the circling area or established on the papi.