EEA spouse in London: When can we apply for DCF?

I realize that if I marry a UK spouse, I would be eligible for FLR in two years, but with a spouse from the EU (living in UK),it will take me FIVE years to gain FLR.  Does this mean that I would need to wait five years to apply for DCF to get my EEA spouse legal into the US?

Any insight would be helpful.

Hi, I was a EEA spouse living in the UK also (moved back to the US in July!) You are pretty much "safe" to attempt DCF once you have been living in the UK for 11 months or so. Good luck!