ORO.AOC.125 Non-commercial operations of aircraft listed in the operations specifications by the holder of an AOC
(a) The holder of an AOC may conduct non-commercial operations with an aircraft otherwise used for commercial air transport operations that is listed in the operations specifications of its AOC, provided that the operator:
(1) describes such operations in detail in the operations manual, including:
(i) identification of the applicable requirements;
(ii) a clear identification of any differences between operating procedures used when conducting commercial air transport and non-commercial operations;
(iii) a means of ensuring that all personnel involved in the operation are fully familiar with the associated procedures;
(2) submits the identified differences between the operating procedures referred to in (a)(1)(ii) to the competent authority for prior approval.
b) An AOC holder conducting operations referred to in (a) shall not be required to submit a declaration in accordance with this Part.
It means that part NCC has nothing to do with it. The only thing that counts is your OM, and hence your CAA gold plating posture. For instance part NCC requires a 45mn final reserve instead of 30mn for part CAT jet operators. What does your CAA think about it?