Re CAR 100, to my comment that 99% of pilots would ordinarily think that it would not apply unless you were actually under air traffic control, PC said he had legal advice that any instruction/directive to an aircraft by an ATC would come under CAR 100 regardless of the airspace category. I pointed out that CAR 100 probably pre-dated Alphabet soup airspace by many years (probably decades, actually).
There is a major major disconnect here between commonsense/logic and what OAR is using as it's prime feature to replace simple old Class D. I wouldn't mind betting that any legal action by CASA using CAR 100 would fail pretty quickly.