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It is bassically accepted that there were several merchantvessels under construction by 1939 that were certainly suitable for converion into MAC vessels, although why would someone do so, if there was no war at sea, until september 1939? By that time, there still was no reason, since the threath of the U-Boote still had to be revealed, as did the use of the FW-200's. The MAC is just as its name indicates, a Merchant Aircraft Carrier as an emergency stopgap, untill more purposely build vessesl appeared.

Technically more vessels could be addapted, but this would be resulting in too much work in ports and yards, also depriving badly needed cargoships from the supplylines for the time needed to convert them. The number actually converted is 19, of these two were converted from Dutch tankers and operated by the Dutch. These 19 fullfilled their task, until the CVE's came into service in sufficient numbers.

The minimum requirements for conversion were a speed of 14 knots, flightdeck of 490/62 ft., originally, but scaled down to 11 knots and 390/62 ft. Six graincarriers and four oilers building were converted and activated in 1942 and 1943, while nine existing tankers from before the war were converted too. None was lost to enemy action during their MAC duty and all were serving postwar as intended merchant vessel.

That is correct, although you also noted why the need for such ships early on was not deemed necessary, since losses by either U-Boote and/or aircraft to shipping in the beginning of WW2 were not that serious at first, untill the Germans perfected their Wolfpac concept and began to make use of the long ranged FW-200 Condor patroll aircraft in conjunction to the U-Boote. As long as such things were not revealed, there simply was no need for putting aircraft at sea to either hunt down submarines and chase away enemy aircraft, since the other Lufwaffe airplanes were almost primarily used in the supportrole of the groundwar and U-Boote were only few in numbers at first.

Technically the British could construct MAC ships early on, but the Allies were still to learn the hard way the war at sea had changed from classical gun to gun fights towards submarinewar and aircraft threats. Not untill 1941 this was revealed, since the Germans still needed time to complete their conquest of Northern France to get the Atlantic ports for the U-Boote and they also needed time to construct sufficient numbers of them to make their weight count into the war at sea.