61.395 (2) applies to all flights, whether VFR or IFR:
The holder of a pilot licence is authorised to pilot, during take-off or landing, an aircraft of a particular category carrying a passenger at night only if the holder has, within the previous 90 days, in an aircraft of that category or an approved flight simulator for the purpose, conducted, at night:
(a) at least 3 take-offs; and
(b) at least 3 landings;
while controlling the aircraft or flight simulator.