Does anyone know which member states have applied for derogations?
EASA have promised a list "soon"
I suspect it is embarrasingly short.
It is interesting that EASA chose to use the term "operator" rather than owner, or beneficial owner, or other such term. I can only conclude that they had reason to be a little vague, and perhaps they may have been afraid to contradict ICAO principles in some way.
There are two possibilities here.
1) They got good legal advice, and did this for a clever reason. One could speculate on what that reason might be. If they followed ICAO provisions and hung this on the "nationality" (citizenship) of the pilot, it would push corporate operators into firing their EU-passport holding crews and replacing them with crews holding non EU passports, which would be a massive own-goal. It is easier to understand why EASA did not propose long term parking limits: this was tried by France (2004) and the UK (2005) and both were hastily abandoned when somebody with a brain realised it would be unworkable (and easy to get around for the big boys). Hanging this on the "operator" is more subtle but leads to easy work-arounds for the bigger boys. It does capture the small private owner quite well though, IMHO, and whose only option would be to syndicate-out the aircraft to a non-EU operating company which then runs a booking website and effectively controls the aircraft.
2) They didn't get good legal advice and developed this in the committee. I think that option is more likely. The wording is far too vague to have come from a lawyer.
Where are the authorities on the scale of one to ten? Maybe Germany is at one and will soon arrest pilots flying IR on FAA licence? UK must be at 10??
UK is definitely at 10 - a top level contact told me the other day they have no clue how to interpret this.
Perhaps a useful way to see this is to examine each country's previous attitude to N-regs.
Germany was easy with them, as were most others. One well known exception was Denmark which imposed vague long term parking controls and did sporadic fines. The well known "zero VAT" lawyer got fined a few hundred euros. I think Norway is similar. But I see no reason why most of Europe should suddenly want to do anything.