For clarity, for the holder of an FI certificate the entry requirements to the IRI 'course' are reduced to 200 hours time under IFR. If you are a line pilot with no FI cert then it's the 800hrs. However, that's not the point here...
As Beagle states, to log IFR then you must be the holder of an Instrument Rating or IR(R) and following IF rules... 1,000ft above blah blah blah. It's irrelevant what conditions your in as IFR can and does take place in gin clear VMC. IFR outside CAS and without a minimum traffic service...... not for me, thanks.
I suspect there are instances of 'creative accounting' in some of the claims arriving at the Authority.....hence the quiet moments. Just sayin'.