[Irv Lee]

Well they just changed it. https://www.caa.co.uk/publication/download/22023

Lesson to learn for:
1- All the FCL pilots who have an hour of training in their annex 1 aircraft (eg a permit aircraft) flown OUTSIDE an ATO or DTO environment and then (WRONGLY) used it since late 2019 as the training hour contribution to the 12 hours to claim an SEP (or TMG) revalidation by experience signature,
or
2- used a similar hour in such an aircraft and (WRONGLY) used it as part of the self-assessed rolling validity for a LAPL(A),
or
3- all the CRIs and FIs who have (WRONGLY) used fcl.945 privileges to sign off an SEP revalidation by experience after conducting an hour of training with an FCL licensed pilot in an annex 1 aircraft (eg permit) outside the ATO/DTO environment
THEN:
the lesson is really: Next time someone comes along with a new regulation that sounds almost too good to be true, try to remember to ask what they traded in or paid to get it. Remember all the virtual applause when someone in 2019 came down the European mountain, announcing that the burning bush had decided that p1 hours in fixed wing microlights could count towards sep revalidation or lapl validity? Was no-one at all suspicious how this had been 'bought'? What you weren't told was that this had come at a price, and the price was to be paid by fcl licence holders who flew annex 1 aircraft - which was that you would have to involve a DTO or ATO for your training hour if it were in your annex 1 aircraft, if you wanted to count the hour to either revalidation by experience or lapl rolling validity.
Anyway, the regulation that should have been exempted on Jan 1st 2021 (if not 59 minutes earlier) has finally been exempted (for future revalidations)