How can the CAA insist on an ADF fit when it is not a legal requirement for IFR flight??
Thats a subject many times done to death and the same requirement always come out of it, while the majority of IAPS have an NDB an no alternate for the missed approach procedure you will need an ADF. There is little to no chance that the CAA are going to allow you to use a GPS to replace an NDB when it is not approved on the plate.
You do not need an NDB for enroute navigation but you need one for an approach or missed approach. catch 22....
But there is no such requirement in the AMC & GM for FAA-to-C-bM IR conversion.
Something else for you add to your list and tell the CAA that they are wrong about Beagle.