While I agree with 421C on the technicalities, I fully expect the FTO business to sabotage the CBM IR in every way they can, because about 30hrs of the required instrument time (yeah I know they call it "IFR time" but a plain PPL could log time flown IAW IFR) can be done with freelance instructors, and any ATPL cadet who is clued up (most aren't but some will be) is going to spot the cost saving opportunity.
People don't change.