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#1566230
Yes/ no answer isn't possible (sorry).
Instead, it depends on which privilege the CRI intends to exercise.
eg
Training for initial issue of Class Rating - ATO required (FCL.725)
Refresher training for Class Rating renewal - ATO required (FCL.740)
Refresher training for SEP Class Rating revalidation - ATO not required (FCL.740.A(b)(1)(ii))

References from the Aircrew Regulation Reg(EU) 1178/2011
Hope this helps.
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