Good point. Clearly when they established the rules the process was not supposed to take years. So you could take the test and accurately fill in the application form.
My understanding is that the way it works now, what you write in the application form is simply your own evaluation of your language skills. One suggestion is that you go to an english/french language training centre and ask for a (sometimes free) evaluation.
But what you need, if you are not taking the test before applying, is to make an honest assessment of your abilities. Eg., if you are applying with 67 points, assuming you speak "moderate english", and later the test reveals you are at the "basic english" level, then you're in trouble.
Personally, I am not planning to take the ielts. I'll claim high proficiency in english (first official language) based on the facts that I took a 4 month ESL course in Canada, then a master's degree (meaning I wrote a report and presented the results of my reseach in english), also in Canada, that I won a prize for "best oral presentation" at a conference, and finally, that I use english on a regular basis at the workplace.
Now, for French... I'll probably take the TEF. Even though I live in France, I don't have enough evidence to make a strong case. But like I said, this is not something that worries me too much, because I don't need those points. (even if I only get "moderate proficiency" in english and "basic proficiency" in french, I still score 69 points)
(but wait for the opinion of someone more knowledgeable...)