UK investment: Can a 1 year Convertible Note or Advanced Share Agreement (ASA) work for EIS tax relief?

HMRC have limited EIS on Advanced Share Agreements (ASA) to 6 months. That is, the conversion to shares must be limited to within 6 months for an ASA to get EIS relief. That’s a big restriction on UK companies using ASAs.

But do longer ASAs actually still work fine?

Suppose you have an ASA with e.g. an 18 month backstop date.

This is not itself eligible for EIS tax relief.

However this should turn into shares at a conversion event – normally a funding round. At that point: Money has been invested for shares. Provided the criteria for EIS are met at that point – Is that OK for claiming EIS from that event? Do HMRC know or care that the money was transferred a year earlier?