The updated guidance is now more stringent as it states on page 49 that:
“In assessing whether a person has complied with immigration requirements over the previous 10 years, you must take into account whether they were subject to the EEA Regulations 2016 or the Immigration Act 1971 and whether they complied with the relevant requirements.”
The 2019 version of the guidance did not make explicit reference to the EEA Regulations. It is also worth noting that page 45 has been updated in relation to what amounts to non-compliance with immigration requirements. Again, reference is now made to a failure to comply with the EEA Regulations.
So it would appear that a European citizen will have their immigration history scrutinised for 10 years to determine whether they have resided in accordance with the EEA Regulations. This is compounded by the fact that the guidance suggests comprehensive sickness insurance (CSI) must now be held for 10 years (rather than five) to qualify for citizenship.