bookworm
Yes you may well be right though I would perhaps differ as to the degree. The JAA PPL has been out for about 3 years. Anyone who learnt to fly for a real purpose would have done the PPL and went on to an IMCR or IR ASAP; it was obvious to me within a few weeks of starting the PPL training that a PPL alone is nearly useless for flying for any purpose (due to weather). I don't think that many "sunny day only" pilots will go for an IR.
But regardless of the interpretation, the IR % is still very low compared to the USA.
Regarding the later posts here, I disagree that an IMCR pilot should call a PAN upon inadvertent entry into IMC. Your training, if current, is more than adequate for flight in IMC, of any duration (subject to fatigue, presence of an autopilot) and an IAP at the far end. If you haven't flown for 23 months and 29 days and can't handle it, that's a completely different story and nothing whatsoever to do with the IMCR. You could be an ATPL; it would make no difference.