Although upset prevention and recovery training is only required for the CPL/ATPL, loss of control is not exclusive to commercial operations! It makes sense to make similar training available as widely as possible to the private pilot. However, by making upset prevention and recovery training the preserve of the aerobatic rated instructor, the regulator may have unintentionally restricted access for the private pilot to such vital training.
The issue would seem to lie with the training and privileges of the flight instructor. While it may not be necessary or indeed practical for all instructors to hold the aerobatic rating, it might make sense to include positive g manoeuvres and upright spin teaching privileges to the basic FI rating. This would allow UPRT, appropriate to the private pilot, to be offered by a much wider range of DTOs/ATOs. This could be achieved using semi aerobatic aircraft which are somewhat more available and affordable than the fully aerobatic aircraft operated by ATOs offering UPRT at present.
Many loss of control incidents occur at low altitude, with the aircraft impacting the ground before a full spin can become established. It's also rare for these situations to result in inverted flight. There would seem to be a major benefit from improving recognition of the impending loss of control, through UPRT with little risk of such training manoeuvres requiring more advanced aerobatic skills from the instructor.
Look forward to other peoples views ... especially instructors.