Davina,
It really does depend on your Flight Operations Inspector, mine have always been good sensible chaps if you approach them with the right level of humility and ask them for advice when discussing such issues.
The requirements are contained in Appendix 2 to Ops 1.175 (i) and ACJ OPS 1.175 (i) of the JAA Temporary Guidance Leaflet (TGL) 44 which has replaced the JAR OPS section 2 as the acceptable means of compliance (AMC). TGL 44 is available on the net if you need it, but the relevent part is here;
1. General. Nominated Postholders should, in the normal way, be expected to satisfy the Authority that they possess the appropriate experience and licensing requirements which are listed in paragraphs 2 to 6 below. In particular cases, and exceptionally, the Authority may accept a nomination which does not meet the requirements in full but, in this circumstance, the nominee should be able to demonstrate experience which the Authority will accept as being comparable and also the ability to perform effectively
the functions associated with the post and with the scale of the operation.
2. Nominated postholders should have:
2.1 Practical experience and expertise in the application of aviation safety standards and safe operating practices;
2.2 Comprehensive knowledge of:
a. JAR-OPS and any associated requirements and procedures;
b. The AOC holder's Operations Specifications;
c. The need for, and content of, the relevant parts of the AOC holder's Operations Manual;
2.3 Familiarity with Quality Systems;
2.4 Appropriate management experience in a comparable organisation; and
2.5 Five years relevant work experience of which at least two years should be from the aeronautical industry in an appropriate position.
3. Flight Operations. The nominated postholder or his deputy should hold a valid Flight Crew Licence appropriate to the type of operation conducted under the AOC in accordance with the following:
3.1 If the AOC includes aeroplanes certificated for a minimum crew of 2 pilots - An Airline Transport Pilot's Licence issued or validated by a JAA Member State:
3.2 If the AOC is limited to aeroplanes certificated for a minimum crew of 1 pilot - A Commercial Pilot's Licence, and if appropriate to the operation, an Instrument Rating issued or validated by a JAA Member State.
I am happy to discuss with you if you wish, just PM me.
Regards
MM