I've finally found something about EASA part fcl on the website.
FCL.915.IRI IRI — Prerequisites
An applicant for an IRI certificate shall:
(a) for an IRI(A):
(1) have completed at least 800 hours of flight time under IFR, of which at least 400 hours shall be in aeroplanes;
and
(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraph
FCL.915.CRI(a).......
Nowhere talks about 200hrs if you already a FI.