Interesting times ahead, as we don't do a PPL test in our 150 hr course. The regs don't seem to give guidance as to when the timer starts. Does 2 weeks of English before starting "flight training" count. What about if a student has trouble passing ICAO 4 English. That bit can be a problem occasionally. A run of bad weather can seriously delay students, it can go over 15 months to pass the CPL if you get a bad 2 or 3 months of weather and an ICAO 4 fail, and that is for students who are in class 5 days a week.
The reg doesn't seem very well thought out.