Probably a mix of each? On the one hand, the Wardenship isn’t lands and castles – it’s a royal appointment – so it doesn’t quite fall under the Kingsguard vows. On the other hand, it’s possible Ned just assumes that Robert will eventually release Jaime from his vows to please Tywin.
But most likely, GRRM just hadn’t made up his mind about that particular aspect of the Kingsguard yet.