Unfortunately, there is nothing new about 'grey charters' which this one certainly was. There is nothing grey about them though. Want to fly someone or something in return for money?......get an AOC. It's that simple and entirely black or white. The regulation is there, but the policing isn't. We made the conscious decision to get out of the King Air charter market because we simply could compete with illegal charters, or bull**** 'private flights' where the passengers 'lease' the aircraft from the owner, then hire a pilot separately.....(Illegal charter dressed up to look like something else). Me and many others have highlighted this to the CAA on many occasions and yet they do very little about it. It's a shame to say that the lack of action by the authorities, (EASA and the national regulators) makes them complicit in this dreadful and entirely avoidable loss of life.
And don't kid yourselves that this is limited to small piston aircraft. It goes up into some very high end biz jets too. On private cat, the safety margins are completely eroded. No margins on RWY length required, no limits to crew duty hours, crew training is basic and falls way short of AOC standards and the whole process has hardly any regulatory oversight. It's a farce that is ripe for smart arses who revel in profiteering by ducking and diving around the regulations at the expense of best practice and safety of those on board that are ignorant to risks they are taking.
This poor footballer who knew nothing of the complex regulations concerning air charter simply wasn't protected by either the regulator or the industry. And a naïve pilot who wasn't protected from his own error of judgement.