The OSD are recommendations
Not quite, the OEB reports were recommendations but the OSD is not. From the Robinson OSD, for example:
In accordance with Commission Regulation (EU) No 69/2014 of 27 Jan 2014, the Operational Suitability Data contained in this document are identified as follows:
[M] .Mandatory Operational Suitability Data, bearing the status of rule (see GM No 3 to 21A.15(d))
[AMC] Non-mandatory Operational Suitability Data, bearing the status of Acceptable Means of Compliance (see GM No 3 to 21A.15(d))
The requirements for pre-solo experience and instructor qualification are both marked
[M]
No one can afford a 20 or 35 hours minimum type rating course
The requirement for 20 hours before solo applies only to pilots who do not hold a licence (i.e. it applies to PPL students not to the type rating).