Sorry to 'answer' your question with another, but I is confused. Do 'EASA' actually have any 'rules'? I was under the impression that nothing was effective until April 2012. I would assume at the moment that EU-OPS pubs are the regulatory?
I sit waiting to be educated.
Edit: There you go - found it!
http://www.pprune.org/tech-log/46257...sa-eu-ops.html. Someone else confused.
I tell you - I would not wish to be involved in trying to set up an AOC or whatever it will be called right now.