If you mean - he has a valid EASA licence with a SEP rating but doesn't meet currency/revalidation requirements
I was thinking more along the lines of valid EASA (lifetime) licence but SEP rating not valid, as per ratings page on licence... Yet has a current flight review for his §61.75 FAA certificate. Both medical and licence for EASA would be in date, just not SEP rating.
What are your thoughts?
This is what I was getting at earlier as far as the underlying EASA licence must be valid. But, if it is in fact not valid due to no current SEP, then would a based-on certificate take that into account when there is no such FAA SE rating?