I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?
My question was an open one, and you've answered it. The "difference" is in the theory and the ATO requirements.
On the former, at the risk of being labelled an IMC rating detractor (which I am not), I do worry a bit that the IMC rating theory is both light and outdated. Unless I've missed an update of the syllabus, QGH procedures, VDF and ADF are unlikely to take the pilot far in the 2016+ world of IFR operation, where every instrument runway end is supposed to have APV and NDBs will have disappeared. The proposed CBM-IR has halved the theory syllabus. Nevertheless, there's lots of scope to improve on the examination administration, and I'd like to see it be as easy to take the IR TK exam as it is in the FAA world.
On the latter, organisational requirements should be at the top of the hitlist of EASA disproportionate rulemaking to be rectified in the wake of the GA Safety Strategy. Again, we need to make the European IR as accessible as the FAA IR. If the IMC rating had by some sleight of hand been made into a European rating, the ATO requirements would be no less burdensome than they are for the CBM-IR. It was simply the (misguided) European way to assume that everything to do with aviation needs an approval certificate, even if it is just an exercise in box-ticking.
On balance, I remain a supporter of the retention of the IMC rating in the UK, just as I know BEagle supports, on balance, the adoption of the FCL.008 package of CBM-IR, EIR and sailplane cloud flying rating.