Hello Kronicklez,
In my opinion, it shouldn't work because instance-type forwarding doesn't have any interfaces associated with it. However, the below KB article explains the Dual-ISP failover scenario using instance-type forwarding, please take a look - https://kb.juniper.net/InfoCenter/index?page=content&id=KB22052&actp=search&viewlocale=en_US&searchid=1350650857447
They didn't call the routing-instance under rpm hierarchy but they imported the routes to the routing-instance.
If you think the route import/export is not feasible in your network, you can change the instance-type from forwarding to virtual-router and it won't break your FBF configuration.