If a piece is taken, repeat the position of the king. If a pawn is promoted (and there are more than than the starting number of the piece it was promoted into) repeat the position of the piece it was promoted into.
1 bit for whose move it is. (193b)
3 bits for the en-passant column. (196b)
50 move rule (I suppose 7 bits, as you need it in ply?) 203b. Then the data for the extra pieces, in the order encountered if any. ?×6b (how many are possible? There are 16 pawns, but I suppose it isn't possible to promote all)