when part FCL was first introduced there were a number of current FICs who were teaching for the IRI without holding an IR in the UK
That of course resulted from the retention of the "No Applied Instrument" limitation which was retained by the CAA throughout the JAR period. The initial reason was because nobody had bothered to update the licensing software. They were however qualified to teach for the removal of this restriction because they held the qualification themselves and in most cases had in-built IMC privileges in their National licences. Few actually taught for the IR so it was perfectly legal to teach for the IRI (restriction removal) so long as they held the rating and were qualification to fly IFR. The EASA regulation is much the same as the JARs and to teach for a rating you must hold it but, where does it actually say that to teach for the IRI you must hold a valid IR? The privileges if the IR(R) which permit flight in the required circumstances in the UK do not prohibit this activity!
On dear!!! Fancy having to be qualified to teach something.
There is quite a difference between not being qualified and finding that some administrator has shifted the goal posts for many of those who have been adequately qualified for a number of years and of course are considerably experienced. The waters have been muddied and their remains a lack of clarity around existing privileges.