It does not state actual or simulated IMC, so simulated IMC would be accepted. If it stated flight in actual IMC only may be logged then it would be a contradiction.
framer - VFR pilots may navigate totally without reference to the ground if using radio navigation as well. The difference is an IFR pilot may operate below VMC, that is in IMC conditions, and fly only by aircraft instrument reference for flight path guidance.
I have found that it is very important for EFIS, autopilot equiped pilots to be vigilant with maintaining IFR scan currency. It is easy to get complacent whilst everything is working properly and you just have to watch the FMS/autoflight do the job. The most likely time you may loose your primary flight displays is at night in IMC after a lightning strike or surge due high power demand.
There have actually been a number of large aircraft accidents caused by flight crew disorientation at night/IMC when proper scanning and understanding of the aircraft displays would have averted the disaster, this includes A320 and 737 types. To say that currency does not matter just because they fly every day is complete rubbish.