Thanks for the input.
I think the interpretation from the authority is the same. Please note, for the time being I am only considering the SEP(L) IR-I.
Directly copy/pasted from Part-FCL. Subpart J, Section 6 regarding IR-I, it says: "FCL.905.IRI IRI — Privileges and conditions
(a) The privileges of an IRI are to instruct for the issue, revalidation and renewal of an EIR or an IR on the appropriate aircraft category.
(b) Specific requirements for the MPL course. To instruct for the basic phase of training on an MPL course, the IRI(A) shall:
(1) hold an IR for multi-engine aeroplanes; and
(2) have completed at least 1 500 hours of flight time in multi-crew operations.
(3) In the case of IRI already qualified to instruct on ATP(A) or CPL(A)/IR integrated courses, the requirement of (b)(2) may be replaced by the completion of the course provided for in paragraph FCL.905.FI(j)(3)."
And further:
"FCL.915.IRI IRI — Prerequisites
An applicant for an IRI certificate shall: (a) for an IRI(A):
(1) have completed at least 800 hours of flight time under IFR, of which at least 400 hours shall be in aeroplanes; and
(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935;"
If a student on an integrated programme can not be instructed by an IR-I (without FI-IR) due to the fact that the student does not hold a specific license, then the IR-I should be able to teach the same integrated students classmate, if he/she was holding a PPL or CPL from before starting the programme. Or; a student doing a PPL skilltest on his/her own basis during the integrated course thereby suddenly holding a valid license. Hence I do not see the connection between the Modular and Integrated programs.
Further; If a student follows an MPL-programme, he/she do usually not take out a PPL/CPL license during the course. Therefore an IR-I should not be able to teach IFR on the MPL-programme due to the fact, the student do not hold a valid license (PPL, CPL or similar). But from the paragraph attached above, it says an IR-I can teach MPL-students if the IR-I fulfills the requirements regarding experience etc. But it is not stated, the instructor needs a specific FI.
I am still unable to find any legislation where it states, an IR-I can not teach candidates who are not holding other licenses than a solo-permit (which in my humble opinion is considered some type of a "license"/"rating" - the student is however flying solo around the country). If any of you guys have a link to any documentation, please advise.
Thanks for the discussion!