Originally Posted by
EXDAC
I have not logged any IFR time and I hold FAA instrument airplane and instrument instructor ratings. There is no place in any of my log books to record IFR time. I have only recorded instrument time and that is subdivided into "actual" and "simulated".
To log actual or simulated IMC you would have been IFR. As a CFII teaching for the IR you would have been IFR for every flight. As PIC. Most IFR training flights don't actually land, so you might not often meet the FAA definition of cross country but I believe you would meet the EASA definition just by doing an approach. You might find that all you need is a pen.
Originally Posted by
EXDAC
Does EASA actually place some value on flying in VMC on an instrument fight plan. What particular skill does that require?
Remember this particular CBIR route is all about converting an IR to an IR so you've already demonstrated that you can fly on instruments. The 50 hours PIC under IFR is there to offer those with some IFR experience but no ATP a test-only option, whilst stopping the masses from skipping the regular 15 hour route.