Are we over-thinking it? Can we not simply push the government into accepting that an "internet connection record" is simply when the CPE gets a working connection to the ISP, so for a domestic user it's when the PPP session comes up on their modem/router, so the ISP just records the time it starts and stops along with the IP addresses.
For a near permanent connection such as a businesses 100M fibre, it's when customer's router is first turned on, until their service is ceased at the end of the contract? Ok, I'm probably being naive and optimistic.