I would interpret the MCF requirements defined for the ‘Operator’ being applicable to both AOC and NCC.
Whilst I cannot qualify the origin of the regulation, I would use the thinking that the regulation was wrote with the complexity and size of the aircraft in mind.
An identical aircraft could be owned / operated by both NCC & AOC but would be subject to required maintenance standards.
I have been involved in AOC MCF directly but not NCC, although I know of privately operated jets undergoing MCF I am unsure if regulated or by owner request.