Interesting point RNT11,
I was always lead to believe it was only the IR that locked the ATPL theory exams. But from re-reading CAP804 again the 7 year validity may only be the case towards the issue of an ATPL and not the CPL. Are you suggesting the 36 month validity still remains if you wish to use the ATPL theory exams for the issue of a CPL regardless if you hold an IR on your PPL? Its not very clear in that regard in CAP804, but then what is!
With referenceto CAP 804, Part 1, Section 4, Part A, Page 4, FCL.025
(c) Validity period
(1) The successfulcompletion of the theoretical knowledge examinations will
be valid:
(ii) for the issueof a commercial pilot licence or instrument rating (IR), for
a period of 36months;
(2) The completionof the airline transport pilot licence (ATPL) theoretical
knowledgeexaminations will remain valid for the issue of an ATPL for a
period of 7 years fromthe last validity date of:
(i) an IR enteredin the license;