Hmm, I am still not convinced that the pilot is the operator. If he is not then I suspect if the operator is an off shore trust or an off shore company then the pilots will be free to continue as they always have.
FWIW I was chatting to a barrister mate of mine today who has a passing interest. I emailed him the relevant proposed regulations and he was of the same opinion.
It seems far more likely to me EASA are after owner operator pilots who are resident in the EU.
I do however think that pilots who own their aircraft via a trust, are UK resident and have not ensured they are operating in accordance with SOPs laid down by their trustees could be vunerable.