Under the new JAR regs you can still be a FI without a CPL. However you cannot be paid to instruct, you also have to pass the CPL theory exams and an approved FI course! This would obviously cost a considerable amount of cash, I'm sure that instructing is rewarding in terms other than cash, but I think that most people going this far would complete a CPL and hopefully be a least be paid some form of wage for their hard efforts(I hope so I'm studying for an CPL/FI(R)my self).
Hope this throws some light on the subject, I believe this information is correct as of today but who knows by tommorow?