Hi, mind if I ask something to clarify please?

So, the initial visa is of course for 30 months. She entered the country on the 27th April 2013.
The visa runs out on 09/01/2016.
So, she will have been here for 30 months to meet the residency on the 27th October this year - 2015.

So am I right in thinking, we could apply 28 days before this date - say about the 30th September(ish)? Or up until the end of October?

The reason I am asking, well it's this new language requirement. Her original pass was in ESOL, which of course is now defunct, but can be used in applications up until the 5th November 2015. Be good then to get applied before then.
I know she could pass the test in IELTS, but they have a validity of 2 years, and if she had to pass this to apply for the FLR, then it would be a bit crazy as she'd have to retake it once again before the ILR.

Many thanks again