ILR Covid Concession Qualifying period

[nebulousowl]

Hope it's ok for me to ask the same question here. I think I know the answer that the below is correct, but I would greatly appreciate a 2nd pair of eyes on this (consider the ILR changes coming up, I am keen to apply for the ILR as soon as possible):

Tier 4 Student Visa from August 2016 to 2020.
Whilst I was on Tier 4 and living in the UK, got Job for Tier 2 with Details below.
My COS was for 2 months (September 2020, had to be used by December 2020).

COS Issue Date: 01/09/2020
COS Work Start Date: 05 Oct 2020 End Date: 04 Oct 2023.
TIER 2 Visa Application Submission Date (I was living in the UK at this point on TIER 4): 04/09/2020.
Started work on 5th October 2020 prior to getting TIER 2 application decision due to COVID delays
TIER 2 Application successful and granted: 28/10/2020
BRP: Start date 20/10/2020.
BRP End Date: 05/10/2023
This visa was renewed in September 2023 as a skilled worker visa, which lasts until 2026.

I believe I am eligible to apply for the ILR 28 days before the visa application date (rather than the employment start date) i.e. 28 days before 04/09/2020 i.e. 07/08/2025?

Is this correct? Also, if so do i need to quote the caseworker guidance in my letter to make sure they understand why I am applying what might appear to be earlier than expected? Thank you!

[nebulousowl]

Missed one detail:

I was outside of the UK due to covid. I re-entered on my student visa on 02/09/2020

[zimba]

Correct. You do not need to quote the caseworker guide. The UKVI knows the rules

[nebulousowl]

Thank you Zimba!