This was just another ill thought-out and ill-enacted bit of the EASA regulation.
The good news is that EASA HQ are aware of the problem, and are under pressure from at least two 'overseas' ATOs to come up with a solution. But meanwhile said ATOs are looking for a short-term solution.
I am aware that one NAA is issuing FCL.900s to at least 3 x ATOs.....