With a question like this I always start by reviewing the LEED rating system selection policy.
Since it specifies that LEED-CI is available for "interior spaces that are undergoing alteration work for at least 60% of the certifying gross floor area," it seems like there is not enough current work to justify the certification.
I have heard about projects going for LEED after construction has started, or even when it's just completed, but two years later seems like a stretch. The policy does say that LEED-CI is for spaces that "ARE undergoing" alterations (emphasis added).
That said, it may be possible, since the policy I've referenced is supposed to be a guideline and not a hard rule, and I don't know of a hard rule about when the work is supposed to take place.
I would contact GBCI to verify that you are eligible to register. I would also carefully review the requirements to make sure you can document them.