IFR time is a stupid concept which no one logs. IFR can be anything really, bimbling along in class G "In accordance with IFR" or on an "IFR flight plan with ATC directed routing".
That was only true in the UK. EASA have now clearly defined what "IFR" and "IFR flight time" really is, what the requirements are and how it should be logged. In fact, the explanatory note that accompanies the NPA goes into this issue specifically.
http://easa.europa.eu/agency-measure...ory%20Note.pdf Para 2.4.2.9.
Here's the draft regulation which details the conversion rules (A.2.IR(A))
8. Applicants for the competency-based modular IR(A) holding a Part-FCL PPL or
CPL and a valid IR(A) issued in compliance with the requirements of Annex 1 to the
Chicago Convention by a third country may be credited in full towards the training
course mentioned in 4 above. In order to be issued the IR(A), the applicant shall:
(a) successfully complete the skill test for the IR(A) in accordance with Appendix
7;
(b) demonstrate to the examiner during the skill test that he/she has acquired an
adequate level of theoretical knowledge of air law, meteorology and flight
planning and performance (IR); and
(c) have a minimum experience of at least 50 hours of flight time under IFR as
PIC on aeroplanes.
So what you need is 50 hours "flight time under IFR".
EASA-FCL.010:
‘Flight time under Instrument Flight Rules (IFR)’ means all flight time during which the aircraft is being operated under the Instrument Flight Rules.
EASA-FCL.600 as it will be amended by this new regulation:
FCL.600 IR — General
Except as provided in FCL.825, Operations under IFR on an aeroplane, helicopter, airship or powered-lift aircraft shall only be conducted by holders of a PPL, CPL, MPL and ATPL with an IR appropriate to the category of aircraft or when undergoing skill testing or dual instruction.
(FCL.825 basically says the same thing, but applies to EIR holders.)
So regardless of how many hours you have logged as "IFR" in your logbook in the past, for the purpose of the conversion you can only count those hours where you were the PIC of an airplane that was operated under IFR rules, and you held an IR.
That doesn't make those "UK-style IFR in VMC outside CAS" logging entries retroactively wrong or illegal, but just means you cannot use them as credit towards the license conversion.
At least, that's the way I see things. It looks pretty watertight to me.