I'm reminded of the instance when we were pre-purposing a 30A switch fuse in a mains room (fed off the busbar) which used to feed a 3ph compressor for something else, there was no neutral provided as the compressor being a true three phase load did not require one, but we now needed one. The installation was from the 70s, so Red, Yellow, Blue conductors in use. I supoose installing black for a neutral in 2016 wasn't strictly in accordance with 7671, but a using blue would have been insane!, can't even remember if I bothered to declare it as a deviation or not
I've had added several neutrals to 3ph circuits in very similar situations and also automatically use black, IMO it is not a deviation. I think it would easily come under the umbrella of H&S / EAWA act to use black.
The only other alternative would be replacing the old colour tails which would be a silly expense.