Is this validity of 36 months for the SEIR or MEIR. For example, if someone takes their Single engine commercial and single engine IR within the 36 months of passing their last ATPL exam. And the 36 months have then lapsed after the issue of SE Commercial and SEIR. Now CPL is valid for life, and if the pilot wants to upgrade to MEIR after the 36 months. Can he do that with those existing ATPL exams, or does he need to sit for some exams?