Its dual flights. Not sure where you copied that reg from but the "VFR" has been removed for a couple of years now. They can now be completed under IFR so you can do them during your instrument training. The flights do have to be completed after your private pilot check ride.
This is the current reg below. The underlined part below tells you that is has to be dual.
§ 61.129 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least—
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.
(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least—
(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.