Actually, it was the Charter company (Island Express Helicopters) that was confirmed to only have VFR certification, and
not to be confused with the pilot's rating. Zoyban was an instrument-rated pilot.
Pilot In Kobe Bryant Helicopter Crash Wasn’t Allowed To Fly By Instruments
Island Express Helicopters, a Long Beach-based company that has seven helicopters registered to it and a related holding corporation,
is certified under Part 135 of FAA regulations to provide on-demand charter services under VFR conditions only, according to FAA records. The regulations impose tight specifications on how air carriers operate, including what kind of weather conditions they can fly in, and pilots must file a flight plan before every trip with the FAA stating how it will be conducted. For a VFR flight, any cloud cover must be at least 1,000 feet above ground level with visibility of at least three miles.
It’s financially demanding and time-consuming for a company to ensure it and its pilots can operate under instrument flight rules, or IFR, says Deetz, and in the Los Angeles area, with its usually balmy weather, he says it isn’t worth it for most helicopter operators, apart from emergency medical services.
[..]
Zobayan, 50, was the chief pilot for Island Express, where he had worked for ten years, according to a
statement on the company’s website, and had 8,200 hours of flight time as of July.
An instrument flight instructor as well, he reportedly flew Bryant regularly and Deetz says he knew the area well.