BF,
The only opinion I have expressed in this discussion is the belief that it would be absurd for no pilot to log pilot-in-command time.
It is irrelevant that EASA does not recognise the term. The received wisdom is that two pilots cannot log overlapping pilot-in-command time, and I have not challenged it here; however, your statement leads to a situation in which nobody logs pilot-in-command time. Such an outcome, in my opinion, is absurd and it should invite, in the case of UK CAA, a regulation 6 appeal.
Part-FCL at FCL.050 on the recording of flight time states:
The pilot shall keep a reliable record of the details of all flights flown in a form and manner established by the competent authority.
Where the UK Air Navigation Order applies, the only pertinent requirement is that the "the capacity in which the holder acted in flight" is recorded. Therefore, if he wishes to comply with art 228 of the ANO, a safety pilot who acted as pilot-in-command must make an entry to that effect in his personal log book. In doing so he attests to his designation according to the definition of pilot-in-command in Part-FCL, which agrees with the definition under US regulations.
Further, the implementing rule at FCL.035(a)(2)(i) states:
An applicant for a licence, rating or certificate shall be credited in full with all solo, dual instruction or PIC flight time towards the total flight time required for the licence, rating or certificate.
While the AMC1 FCL.050(b)(1)(i), on the logging of PIC flight time, states:
the holder of a licence may log as PIC time all of the flight time during which he or she is the PIC
Please just accept that safety pilot hours do NOT count towards licence or rating issue for an EASA licence or rating.
A safety pilot
who acts as pilot-in-command satisfies the abovementioned requirements for crediting PIC time for Part-FCL purposes. Nowhere has it been stated that the safety pilot must act as pilot-in-command.