For the record we would require candidates to hold a PPL before starting the course.
Should any regulators be reading it would be helpful for clarification on what 'hold a PPL' means, we think it means 'have one issued'. Also what does 'start' mean? Obv anyone can study material on their own without participation from an ATO, but does it mean 'register for a course', 'submit progress test', 'open a book', 'buy a book' or something else? Who knows?
This is a recurring issue, usually caused by delays in getting PPLs actually issued. Would be interested to hear how other ATPL distance learning ATOs deal with it.