flight time under ifr only starts counting after you ave got your ir.
That's obviously not the case for UK IMCR holders, but I think there is little point in guessing, since the whole thing has not even been through comitology and could be modified heavily, or even chopped completely.
And, ultimately, the acceptance of previous training will be at the hands of the FTO, who will have zero commercial incentive to accept any of it. So any ambiguity will be resolved in their favour
