That's a nice, succinct explanation of the situation Ryanair finds itself in (and it's a problem entirely of their own making).
The only thing I would add is that there have been suggestions that RYR has also been playing fast and loose with the "900 block hours in 12 consecutive months" limitation by claiming that it only applies to the year that starts in a specific month. So, for example, a pilot could fly 500 hours in the last six months of the defined year and another 500 hours in the first six months of the next year, which would clearly be against both the letter and the spirit of the regulation.