It seems the left hand and the right of the FAA do not talk to each other. What's new?
Buried in the final rule of 61.57 in the Federal Register:
A person would not need a flight instructor or ground instructor present when
accomplishing the approaches, holding, and course intercepting/tracking tasks of Sec. 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator. Only when a person is required to
submit to an instrument proficiency check must a flight instructor or ground instructor be present.
The rationale is that a person is not required to have a flight instructor or ground instructor present when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft. If the person is using a view-limiting device (i.e., hood device) when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft, only a safety pilot is required to be present. If a person is performing approaches, holding, and course intercepting/
tracking tasks in an aircraft in IMC, it is permissible to log the tasks without a flight instructor being present.
Therefore, a person who is instrument current or is within the second 6-calendar month period (See Sec. 61.57(d) for currency) need not have a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of Sec. 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator.
So I think you would need an instructor for the upset events since it just says you don't need one for the approaches and holding. (It's come up before that while you're shooting an approach, you are tracking a course.)
And yet 61.51 tells us an instructor must verify your ATD time for currency.
Pilot logbooks.
(g) Logging instrument time.
(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.