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Is replacing halogen downlighters with LEDs, in a bathroom, notifiable work?

I find the regulations somewhat confusing:
Areas within a kitchen, bathroom, garden or special location
NOTIFIABLE:
...
Adding a lighting point to an existing circuit
...

NOT NOTIFIABLE:
...
Replacing a light fitting
...
Source: http://www.electrical-testing.co.uk/p/articles/diy-electrical-works-is-it-worth-it-and-how-does-part-p-affect-me

Does replacing a set of low voltage halogen downlighters with transformers with LEDs and drivers count as "adding a lighting point" or "replacing a light fitting"?

I suppose it depends if the transformer/driver is seen as part of the fitting?

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