Originally Posted by
rudestuff
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.
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.
Also Czech informed me that I will not be converting my IR under CBIR but under EASA FAA TIP-L bilateral agreement, so I believe this makes the process slightly easier ?