As an EASA Part NCC operator ...we are not a PRIVATE flight ....this is confusing. Part-NCC requires each operator to adhere to the same essential requirements as commercial air transport operators with proportionate rules. Why is there a requirement for the Owner to be on board??[/QUOTE]
You are a private flight, NCC stands for non-commercial operations with complex motor-powered aircraft.
Emphasis on the words non commercial. Just because EU requires you to abide by commercial operations does not mean you are a commercial operator.
The tit for tat may now begin.