The esc guide doesn't stop you doing the cons unit
It tells you that if they refuse the upgrade, but still want the consumer unit, then you carry out a risk assessment
If it was me,my risk assessment would be to have a look at the location of the class 1 fittings, for proximity to nearby piework etc, and test the fittings to ensure they are good insulation values to the metalic parts of the fitting,then between those parts to the pipework
Advize the customer the best bet is upgrade the circuit
If they refuse
Take into account the test + inspection of the fittings,put a warning label at the cons unit about the lack of cpc and plonk all the information on the eic then do the job and get paid