EU Settlement Scheme - Surinder Singh?

I'm British and my fiancee is Russian. We lived together for two years in France from October 2017 to December 2019, I was working while she was studying. We moved back to our separate countries in Dec 2019 and have since got engaged.

My question is: would my fiancee be eligible for the EU settlement scheme under Surinder Singh? We have plenty of proof of the nature of our relationship and how it has continued. I just wonder if I've lived in the UK for too long for that to apply. It's hard to find proper guidance about it.