With reference to your e-mail below, firstly apologies for the delay in replying.

Unfortunately there is a problem with the use of the new rule to obtain a Part-FCL Competency-Based IR based upon a 3rd country IR. The problem is that it has not yet been established how examiners are to be satisfied that applicants have sufficient theoretical knowledge as is required by Appendix 6 to the Aircrew Regulation:

i.e.

8. Applicants for the competency-based modular IR(A) holding a Part-FCL PPL or CPL and a valid IR(A) issued in compliance with the requirements of Annex 1 to the Chicago Convention by a third country may be credited in full towards the training course mentioned in paragraph 4. In order to be issued the IR(A), the applicant shall:

(a) successfully complete the skill test for the IR(A) in accordance with Appendix 7;

(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR); and

(c) have a minimum experience of at least 50 hours of flight time under IFR as PIC on aeroplanes.

The EASA AMC and GM does not appear to provide any information on this and so it seems that the Member State authorities will have to develop their own - hopefully working together to develop common criteria. When this matter has been addressed the UK CAA will provide information for examiners on how the assessment is to be conducted. I would expect this to be by publication of a UK Alternative Means of Compliance. I regret that until the relevant criteria are established, we are not able to accept applications for conversion of IRs by this route.

The CAA will advise when this option is available.

With regards to your additional question if testing in N-reg, you must comply with any national requirements for using N-reg aircraft.

Yours sincerely