I argued with the union about this. I said "I meet the requirements in section 24 H right?" Which is phrased "The only minimum qualifications that shall be established are the following minimum qualifications for Upgrade to any Captain position.... " and they said well the company can have additional requirements when they are regulatory.

The 1000 121 is only required for acting as PIC, not for upgrade, but the company and union keep calling it a "regulatory upgrade requirement." I've flown the left seat in the sim before in initial, and for that matter I wouldn't even be PIC during OE, so there's an additional 25 hours anyway. Oh well, I have enough hours now so hopefully I can get in on this supplemental captain vacancy.