Lots of changes to regs April 2012. If you want a rivetting read, I suggest you try out a google search for eu ops basic regulation. Far more in there than there was in JAR Ops ref state exemptions and requiring member states demonstrate meeting reqirements as far as reasonably practicable. Much of this will be down to interpretation, but i cant imagine them issuing atpls to do so. Too expensive and with obvious retention issues. How they will go about it will be interesting. Gashed would be my best guess.
Its not just licensing; all regulation is required to be met as far as reasonably practicable from my understanding, including subpart Q.