CBTA

Competencies are widely used in aviation.
There are many documents that develop this training "tool" (e.g. ICAO 9868, IATA Guidance Material and Best Practices for Competency-Based Training and Assessment (CBTA), ...).
In the EASA environment, the competences are also recommended in the EPAS 2020-24 and the equivalent within the different NAA.
Putting the focus on the regulation, we find it in the Reg 1178/2011 the use of competences as an element of many courses (IR, MCC, Instructor ...).

However, if we look at Reg 965/2012, seems to be some confusion.
The demonstration of competencies is required in SPA.LVO and indirectly in SPA.DG, but if you look at ORO.FC everything about competencies could be considered in EBT (ORO.FC.146, ORO.FC.231, ...). 

But EBT is not just CBTA, right?
My guess is that this misconception is because EBT has its own implementation rules, as well as recurrent training and checking.

And this is where I want to get to: is CBTA a tool that can be used to train like the legacy method or does it require a specific approval apart from the specific training programme?
Could someone give us their opinion if there is any limitation to train with CBTA within a Command Course (ORO.FC.205) or Either Seat (ORO.FC.235)?

Thank you,