Means of keeping ATPL/IR-theory valid with IR-privileges restricted to third-country aircrafts

According to Article 3 d) in regulation (EU) 2020/723 member states of EASA may issue ratings with restriction to third-country registered aircraft, if the holder fulfills the requirements determined by the third-country. According to information from the European Union Agency for Aviation Safety (EASA) the validity in FCL.025 c) in Appendix I to regulation (EU) No 1178/2011 cannot be based on an IR-rating with a restriction to a third-country registered aircraft. The regulation of validity in that term only refers to IR-ratings issued in accordance with Part-FCL. An IR-rating issued according to third-country regulation does not give credits to other parts of Part-FCL, such as theory, unless otherwise stated in the regulation. 

If you have an IR-rating with restriction to third-country where less than 7 years have passed since the IR-rating according to Part-FCL expired, you ought to complete a proficiency check (PC) with an EASA examiner before 7 years have passed.

If you have an IR-rating with restriction to third-country where more than 7 years have passed since the last IR-rating according to Part-FCL expired, you must perform a proficiency check (PC) for IR in accordance with Part-FCL at the latest on 31^st March 2024.

Please note that there is another possibility to renew a lapsed IR-rating according to FCL.625(e). FCL.625.(e) states the following;

Holders of a valid IR on a pilot licence issued by a third country in accordance with Annex 1 to the Chicago Convention shall be exempted from complying with the requirements in points (c)(1), (c)(2) and (d) when renewing the IR privileges contained in licences issued in accordance with this Annex.

That means that there is a possibility to renew an IR-rating only by performing a proficiency check even though more than 7 years has passed since the IR-rating lapsed. Please note that it assumes that the third-country type rating is valid and that you at some point have had an IR-rating according to Part-FCL. The Swedish Transport Agency recommend to always carry out a proficiency check for IR in accordance with Part-FCL every six year not to risk losing your theory if the third-country type rating becomes invalid for some reason.