My FTO has had it writing from EASA that a student can sit a skills test without the full hours for CPL issue, with remaining hours can be built after the skills test before applying for licence. This was about 3 weeks ago!
EASA have also confirmed in writing of an "error" on a document created internally within EASA has been misinterpreted by examiners/staff etc. due to the admin person creating this document and wording it incorrectly; consequently causing this confusion.
I call BS on this.
If they think differently an AMC would be issued.
Also even if they confirmed in writing it was a mistake - which is unlikely - as this is more like ICAO - then it's still law and we still have to abide by it.
The other states in EASA are applying this it's in their examiner briefings.
I think this is smoke and mirrors by the ATO to be honest but would love to be proved wrong.