This is also the case in Finland right now.
Initially, Finland informed EASA, that they will continue to issue permits for AOC holders to conduct the required landing trainings as before. This information was also passed to the operators.
Around 1,5 months ago, National Authorities had a EASA standardization meeting where EASA pushed everyone to follow the requirement that all the type rating training has to be done thru ATO.
Shortly after this, around a month ago, all the Finnish operators received a notification stating, that as of that day, NO more permits for AOC holder's landing trainings will be issued!!!!
The regulation is clear. The problem is that ATOs conducting simulator training do not generally have any aircraft. And then using the 3rd parties..., well..., then the liability questions come into the play.
On the other hand, it is my understanding, that f.ex. in the UK, the landing practise after the type rating course and the passed check ride is not even considered as a part of the type rating course, and therefore does not need any kind of approval.
Go figure, Europe and EASA, one happy family with the same rules and same treatment for everyone. Or not...
