I'm sure that this isn't what the very clever eurocrats actually meant when they wrote their new rules. I would *guess* they meant 'instrument flight' instead of IFR.
No, the not very clever Eurocrats simply copied it from JAR-FCL 1.330 which has said: "time in accordance with the instrument flight rules" since about 1995. There is no evidence to suggest that the Eurocrats had any comprehension of the process whatsoever.
You don't need an IR
Maybe not with a UK National Licence but all JAA licences state:
JAR–FCL 1.175 Circumstances in which an IR(A) is required
(a) The holder of a pilot licence (A) shall not act in any capacity as a pilot of an aeroplane under Instrument Flight Rules (IFR), except as a pilot undergoing skill testing or dual training, unless the holder has an instrument rating (IR(A)) appropriate to the category of aircraft issued in accordance with JAR–FCL.
The other issue is that there is absolutely no requirement to log IFR time, so nobody has a record of it anyway.
Yet the CAA have objected on the grounds that only FTO have sufficient experience to teach it.
The CAA are only complying with the European rules and have little choice in the matter.