To have your FRMS looked at by CASA you have to have gathered 12 months of data which has to have been analysed over the 12 months by some scientist or somebody.
So if you haven't done this yet or haven't started this then I would say you'll be using the standard numbers in CAO 48, when exemptions finally expire.
I can't see any small company with less than 20 aircraft going down that path, which means there really will not be that many submissions to CASA anyway.