Some of the LED replacement bulbs I have seen will be quite a bit different optically than the original filament designs in terms of origin of light vs the focal point of the reflector/projector.

So there is some logic to the latest regulation change.

We fitted one of the LED full replacement units to our 2012 M3W and like others we found that went through the last MOT OK and is a great improvement for night driving...hope the next MOT will be OK....