If certain GA organisations hadn't responded like petulant children to NPA 2014-28, an RF could easily have become a non-complex ATO with far simpler requirements than are currently in place....
So (if they had the appropriate instructors),your local RF could have provided CbM IR training without the cost and hassle of the current approval process.
But now you'll all have to wait to find out whatever the EASA 'Training Outside an ATO' mob dream up......and that's going to take a while.