General Exemption E 4967 published as ORS4 No. 1329 of 8 Nov 2019 (link).
local copy
Requirement for Part FCL licence Holders to hold the Relevant Class or Type Rating when
Revalidating or Renewing an Instrument Rating for an Aeroplane or Helicopte
1) The Civil Aviation Authority (‘the CAA’), on behalf of the United Kingdom and pursuant to article
71(1) of Regulation (EU) No. 2018/1139, exempts all UK issued Part-FCL licence holders from
the requirement of holding the relevant valid class or type rating when revalidating or renewing
an Instrument Rating in accordance with the amended requirements of (EU) No.2019/1747 to
the Aircrew Regulation, FCL.625(c)(3), FCL.625.A(a)(1) and FCL.625.H(a)(1) and (3)
2) This exemption has effect from 11 November 2019 until 10 January 2020, both dates inclusive,
unless previously revoked.
In the document there is some update about transfer of licences to another authority. They must do it now “without undue delay”. Wonder who that’s aimed at…
A revalidation of the SE Class Rating could be dealt with by the FI bringing the paperwork to the aircraft and signing off the Class Rating revalidation during the flight (after a successful completion of that portion) and then the IR revalidation / renewal could commence.
Would that work?
It is easy enough to keep one’s PPL (i.e. the SE or ME class rating) valid. Even a CRI (FCL745 approved) can do it for you. But the IR expires every year so it more likely to need a renewal, not a revalidation.
I revalidated SEP/MEP/IR in one MEP flight. (The SEP was revalidated based on experience, not the MEP flight).
Although if SEP has expired, you might not be able to do it all in the same day.
It’s RENEWAL!
You can have a temp certificate of licence privileges issued if you do the class rating before the IR proficiency check so don’t need to wait for licence reprint or I suspect most will do the combined class and IR proficiency check
I suppose the logic is that you can’t renew an IR if you are not qualified to fly the aircraft being used which is difficult logic to argue against
Disregard
For renewal it is even more irritating since it means you need to formally renew the class rating and wait for all the paperwork to be completed before you can do the renewal of the IR, rather than doing them all in one go.