The precise wording of the relevant part of FCL.915.FI is, "An applicant for an FI certificate shall....hold at least a PPL(A) and have met the requirements for CPL theoretical knowledge, except for an FI(A) providing training for the LAPL(A) only...." (my emphasis) This would seem not to permit an FI(A) without CPL theoretical knowledge to teach for any qualification other than the LAPL(A), although the precise interpretation is left to the competent authorities. However the UK CAA chooses to interpret the requirement, there are plenty of authorities around Europe that interpret it precisely as it is written and do not permit such instructors to teach for anything other than the licence unless a CRI certificate is also held. It would be wise, therefore, to exercise caution if providing instruction to the holder of a licence issued by competent authorities other than the UK CAA.