NINo and PIP claim

Client is an EEA national who has been in the UK for only a few months. He wants to claim PIP, which will require application of the EU co-ordination rules because of the past presence test, but a further obstacle is that he has no NINo, and was turned away on this account when he called the PIP claim line.

The DWP policy that has been referred to in other posts suggests that, if entitlement to a benefit is established, the DWP should then invite the claimant to a “Benefit Inspired NINo Evidence of Identity interview”, rather than sending him away to get (or at least apply for) a NINo before processing his claim.
https://www.gov.uk/government/publications/la-welfare-direct-bulletins-2020/la-welfare-direct-32020#reminder-la-claimants-without-a-national-insurance-number

Does the same approach apply here, or might it differ, on the grounds that the claimant’s entitlement is itself in question and will have to be referred up the line?