How about the entire FAA, they introduced the 1500 hour rule to stop that happening.
The FAA 1500h was a knee-jerk reaction to Colgan crash, where the FO had 2000+ hours, and almost 1500h upon joining the airline.
And I'd hope there never is, but I cannot at all back down that Simulator UPRT for MPL students is not equivalent to ATPL in a real aircraft
Upset recovery in a C172 has very little to do with that of a jet airliner. In C172 you have immediate response from the throttle at all altitudes and it has real effect on controllability of the aircraft. At FL360 it takes 30+ seconds to spool up a jet engine from idle to any useful thrust. Not to mention if you apply full thrust for stall recovery in a let's say B737, you'll just worsen everything, where as in C172 full power actually helps with recovery.
Horses for courses. You can't teach UPRT for jet aircraft in single engine pistons, just like 3000h of flying C172 in a circuit won't help you flying a B777 on a ULR flight.