We have already seen that if somebody realized after reciting Shaharit that he had not recited Birkot Ha'Torah that morning, he does not recite Birkot Ha'Torah at that point, because this obligation is fulfilled through the recitation of Ahabat Olam – the Beracha recited immediately before Shema. This blessing contains a prayer that G-d assist us in our Torah learning, and it thus suffices to fulfill the requirement of Birkot Ha'Torah, which we recite over the Misva of Torah study.
However, Hacham Ovadia Yosef ruled that this applies only if a person realized his mistake only after he recited Ahabat Olam. If, however, one realized his mistake earlier, during the Beracha of Yoser Or – the Beracha preceding Ahabat Olam – then he should recite Birkot Ha'Torah after the conclusion of that Beracha – meaning, after "Yoser Ha'me'orot" – and before beginning Ahabat Olam. Ordinarily, of course, it is strictly forbidden to make any interruption from the beginning of Yoser Or through the end of the Amida prayer. However, Hacham Ovadia makes an exception in this case, allowing the recitation of Birkot Ha'Torah before one begins Ahabat Olam. This ruling is based on the position taken by the Magen Abraham (Rav Abraham Gombiner, Poland, 1633-1682) regarding the case of a person who heard thunder as he recited Shema or the blessings before or after the Shema. The Magen Abraham ruled that although interruptions are normally not allowed during this section of the prayer service, nevertheless, an exception is made in the case of a time-sensitive blessing, which cannot be recited later, and so one may recite the Beracha over thunder ("She'koho U'gburato Maleh Olam") at that point. This blessing must be recited immediately after hearing thunder, and so it is permissible to recite the Beracha after hearing thunder during Shema or its blessings. Hacham Ovadia applies this line of reasoning to Birkot Ha'Torah. After one recites Ahabat Olam, he will no longer be able to recite Birkot Ha'Torah, and so we may allow a person who forgot to recite Birkot Ha'Torah earlier to do so before the Beracha of Ahabat Olam.
However, although Hacham Ovadia took this position in his work Yabia Omer, his son – Hacham David Yosef – writes in his work Halacha Berura that Hacham Ovadia later retracted this ruling. He explains that a clear distinction exists between this case and the case discussed by the Magen Abraham, as in this case, the individual has the option of fulfilling his obligation through the recitation of Ahabat Olam. A person who hears thunder during Shema or its Berachot will have no other opportunity to recite the Beracha over thunder, but in our case, the individual can satisfy his Birkot Ha'Torah through the recitation of Ahabat Olam, and so there is no need to make an interruption in between Yoser Or and Ahabat Olam.
Others, however, maintain that Hacham Ovadia did not retract his ruling, and it remains binding.
Within Hacham Ovadia's original ruling, there is some uncertainty as to whether he allows also reading the verses of Birkat Kohanim that are customarily read after the recitation of Birkot Ha'Torah. As Birkot Ha'Torah must be immediately followed by Torah learning, it would seem that if Hacham Ovadia allows reciting Birkot Ha'Torah in between Yoser Or and Ahabat Olam, then he allows also reading these verses so the person reads Torah after Birkot Ha'Torah. Indeed, this is what Hacham Ovadia writes in his aforementioned responsum in Yabia Omer. Later, however, in Yalkut Yosef, Hacham Ovadia made no mention of reading these verses after Birkot Ha'Torah in this case, and there is some controversy regarding his intention. Rav Meir Mazuz (1945-2025) asserted that Hacham Ovadia intentionally omitted this component of his ruling, because there is a compelling reason not to read the verses after Birkot Ha'Torah in such a case. According to some views, the reading of Shema qualifies as Torah learning, even though it is read as part of the prayer service (and not for the sake of Torah study), and thus there is no need to add verses after Birkot Ha'Torah in the case under discussion. And, there are Poskim who deny altogether the need to read verses immediately after Birkot Ha'Torah. Hence, we have a situation of "Sefek Sefeka" – a "double uncertainty," as there are two factors that could potentially lead to the conclusion that the verses should not be read. Indeed, there is testimony that Hacham Ovadia changed his mind on this matter and maintained that one should not read verses when he recites Birkot Ha'Torah immediately before Ahabat Olam.
According to the view that a person in this case fulfills his obligation through the recitation of Ahabat Olam, the question arises as to when he should learn Torah to satisfy the accepted view that this is required after Birkot Ha'Torah. As mentioned, some Poskim maintain that reading Shema suffices for this obligation, even though the Shema is read as part of the prayer service, and not for the sake of Torah study. Others, however, disagree, and maintain that reading Shema does not qualify as Torah learning. And, one is not permitted to make any interruption until after the Amida – and, the Shulhan Aruch writes that one may not interrupt between the Amida until after the Tahanunim recited after the Amida. If so, when does one have the opportunity to read words of Torah after Birkot Ha'Torah if he fulfills his obligation through the recitation of Ahabat Olam?
Hacham Ovadia ruled that one satisfies this requirement through the recitation of Ashreh – a portion of Tehillim – toward the end of the prayer service, and through the recitation of the Shir Shel Yom (daily chapter of Tehillim). These qualify as Torah learning, and thus they suffice to fulfill the requirement to read Torah after the recitation of Birkot Ha'Torah. This is true also of Pitum Ha'ketoret and Tanna De'beh Eliyahu.
It should be noted that if a person prays after the final time for Shema, then his reading of Shema is done solely for the purpose of Torah learning, as he can no longer fulfill the Misva of Shema. Therefore, his reading of Shema after Ahabat Olam certainly qualifies as Torah study.
We are left with no definitive conclusion as to the proper procedure to follow when one realizes during Yoser Or that he had not recited Birkot Ha'Torah. Therefore, it is critical to avoid this situation and ensure to recite Birkot Ha'Torah in the morning before Shaharit.
Summary: If a person realizes as he recites the Beracha of Yoser Or that he had not recited Birkot Ha'Torah that morning, it is uncertain whether he should recite Birkot Ha'Torah after reciting "Yoser Ha'me'orot," before he begins Ahabat Olam, or if he should fulfill his Birkot Ha'Torah obligation through the recitation of Ahabat Olam. According to the first view, it is unclear whether he should also read the verses of Birkat Kohanim at that point. In light of these uncertainties, it is vitally important to remember to recite Birkot Ha'Torah in the morning before Shaharit.