There was no 'rule change'. The situation arose as a consequence of the slippage of dates associated with EASA licences. Article 9 of the Aircrew Regulation states:
Credit for training commenced prior to the application of this Regulation
1. In respect of issuing Part-FCL licences in accordance with Annex I, training commenced prior to the application of this Regulation in accordance with the Joint Aviation Authorities requirements and procedures, under the regulatory oversight of a Member State recommended for mutual recognition within the Joint Aviation Authorities’ system in relation to the relevant JAR, shall be given full credit provided that the training and testing were completed by 8 April 2016 at the latest.
Back when that was written, it was assumed that everything
would have been converted years ago, the 'application of this Regulation' being Apr 2012. Which would have meant that the Apr 2016 clause wouldn't then have been an issue.
The CAA identified a pragmatic solution; the 2 month limit applies to a derogation under Art. 14 of the Basic Regulation which can be achieved without a lot of fuss. Further or longer derogations are both more expensive and liable to be challenged.
tobster911, I recommend that you identify a date for the Skill Test as you propose, but when applying to the CAA, stress that the Skill Test is planned for the date you've chosen and that you will need to have received the derogation by then. Do remember:
- Application must be made using CAA Form SRG2137. The CAA estimates that it will take around 10 days to process and issue the exemption and the exemption must have been issued before the Skill Test is taken.
- The administration fee is £53 for an exemption valid for a 2 month period.
- The Skill Test must be passed within 2 months of receiving the exemption