EASA Enroute-IR minimum ceiling?

[bookworm]

The rules as we currently understand they will be are as follows:

FCL.825 En route instrument rating (EIR)
(1) The privileges of the holder of an en route instrument rating (EIR) are to conduct flights by day under IFR in the en route phase of flight, with an aeroplane for which a class or type rating is held. The privilege may be extended to conduct flights by night under IFR in the en route phase of flight if the pilot holds a night rating in accordance with FCL.810.
(2) The holder of the EIR shall only commence or continue a flight on which he/she intends to exercise the privileges of his/her rating if the latest available meteorological information indicates that:
(i) the weather conditions on departure are such as to enable the segment of the flight from take-off to a planned VFR-to-IFR transition to be conducted in compliance with VFR; and
(ii) at the estimated time of arrival at the planned destination aerodrome, the weather conditions will be such as to enable the segment of the flight from an IFR-to-VFR transition to landing to be conducted in compliance with VFR

AMC1 FCL.825 En-Route Instrument Rating
CONDITIONS FOR THE EXERCISE OF THE PRIVILEGES OF AN EN-ROUTE INSTRUMENT RATING (EIR)
In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC. If the required meteorological data are not available for the destination aerodrome, the flight should be planned to a nearby aerodrome for which such meteorological information is available. An IFR/VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points.

GM1 FCL.825 En-Route Instrument Rating
GENERAL
Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.

I think it's clear that at the VFR/IFR and IFR/VFR transition points and levels, flight should be possible under both VFR and IFR. Thus if they are outside controlled airspace, the ceiling at the transition point should be at least at or above the minimum IFR altitude (usually 1 000 ft above the highest obstacle within 8 km), and if they are inside controlled airspace, the ceiling at the transition point should be at least 1000 ft above the minimum IFR altitude (i.e. 2 000 ft above the highest obstacle within 8 km).

The wording is also such that if the destination or alternate is in controlled airspace, the ceiling there should be forecast to be at least 1500 ft and the visibility at least 5 km. It does not appear to have taken into account the possibility of a transition from IFR to VFR outside controlled airspace and a SVFR arrival.