The problem is that EASA has not defined the term 'operation'. It defines 'operator' as "any legal or natural person, operating or proposing to operate one or more aircraft", which is not a great deal of help. What EASA considers to represent 'operating' an aircraft may well differ from what you or I might think.
I have a feeling that if challenged to provide a definition, EASA will say that this is up to the courts in the member states to decide!