
Originally Posted by
griffin
I just noticed that the actor himself picked up on this as well, wondering if this could be seen as using up one of his regenerations, but will be something they will probably worry about later. Footnote 18 - 'Now, whether this means the Doctor has used up one of his limited regenerations or not is a matter for some future debate, I suspect'
At least someone official has it on the record that this could/should count as a regeneration, because as I keep saying, a physical change is not required for a regeneration to save the life of a Timelord 12 times.