Absolutely Tail Wheel, if CASA were indeed reliable, there wouldnt be forums like this discussing it endlessly with no actual conclusion. Because the laws around this are structured like that. I also heard from a fairy that sometimes regulators make grey laws like this, to allow you to complete operations like this, given you've set it up correctly. But who knows at this point, and please dont take that in writing, ever...
CASA should really consider providing guidance material on this topic. It would save alot of time, headache, money and stress. And it would provide a source for companies to directly refer to, to let them know immediately if what they were doing was right or wrong. Then bring the companies that continue to bend or break the law straight to court.
Just my 2 cents.
Insurance from what i understand will vary company to company. But even outside of that, buisness insurance may pose an issue. Something to look more into.
Squawk 7700: Maybe you should bring that forward with the many outback operators that hire pilots, with those minimums on their charter operations.