it cannot be certain that an FI(A) with less than 200 hrs flight time
under IFR may instruct for the IR(A)
If the privilege is listed on their EASA Licence (as Pembroke says his is), no
matter how it got there, then I would say it is certain that they can instruct
for the IR(A)
(providing they remain suitably qualified eg have a valid IR themselves)
If not, then the whole process of listing Privileges on a Licence becomes
totally meaningless.