For a facility to be used as an approach aid the aerodrome license holder has to provide an ATC Approach Control Service (ANO - Article 90).
No APP service - facility cannot be used an approach aid. FFF's assumption that it would be legal therefore is dubious. Of course if you were to stop the approach at 1000ft then different matter - but then you're just obeying the 1000ft rule. Any lower than that though and you're asking for trouble legally.