When we joined EU, JAR's came into play to relief of many folks as now simple SEP(L) is enough.
The only way that this can be in accordance with JAR-FCL 1 is if the aircraft is considered as single-
pilot. JAR-FCL 1.220(b) requires multi-
pilot aeroplanes to have a type rating and not a class rating. According to the AN-2 flight manual, the second mandated crew member may be a (properly licensed) flight engineer or navigator and so the aircraft may be said to be multi-
crew but not necessarily multi-
pilot. This is significant as JAR-FCL refers to multi-
pilot and not multi-
crew aeroplanes.
Consequently, if the state of registry permits the AN-2 to be flown on a SEP(L) class rating (as, in this case, it does) then the implication must be that it is considered to be a single-
pilot aeroplane for licensing purposes. If it is to be considered as a multi-
pilot aeroplane then, to act as a member of the crew, you must hold a type rating.
Whilst not directly relevant, it is also worth bearing in mind that JAR-FCL 1.215(b)(2) restricts the privileges of a type rating for an aeroplane not included in the 'associated administrative procedures' (i.e. the EASA type rating list) to aircraft registered in the state that issued the rating.
None of the above, however, prevents the recording the hours flown on the AN-2 in a pilot's logbook, which is merely a personal record of flight experience. Whether those hours may subsequently be counted towards experience requirements for future qualifications will be entirely at the discretion of the state of licence issue and will not be binding on other JAA member states.
The same will be true under EASA when Annex II aircraft will be the responsibility of individual states and arrangements put in place by one state may not be accepted by others. It will also be the case under EASA that experience gained on Annex II aircraft will not be accepted towards the requirements for issue/revalidation of an EASA licence or rating.