Germany seems to have gone for a 1 year derogation; that's a translation of that German site by a German pilot. I have no more details e.g. which of the two derogations they have gone for.
I think that quite unlikely.
The real Q is
who decides you are illegal. In these circumstances it can only be a court interpreting the regs (during a prosecution) which are so vague they can be argued about for ages.
If one is talking about prosecutions i.e. a criminal offence then all the pub lawyers thinking they know how an "operator resident in the EU" is defined are not worth anything.
I would suggest contacting your insurer is much more relevant. I did that, and the reply was that in the present circumstances (where even the CAAs don't know what the regs mean) they would not regard the flight as illegal, especially if the paper issue is not relevant to the incident (which it almost never is anyway). It thus appears to me that insurers are not going to try interpreting the EASA regs for themselves, keep their decision quiet, and then refuse to pay out if you have a prang.
As I have written here countless times, I did the
JAA IR not because I was worried about illegality (because the EASA FCL reg is a load of vague self evident crap which nobody will know how to police for ages, if ever) but because of the
insurance angle.
What I did not expect, and nobody else did either by the looks of it, is that the situation would become 10x more vague by most of the EU ignoring the regs totally as if they never read them (which most probably haven't). This makes the insurance angle pretty vague also.
The other reason I did the JAA IR (conversion) is because I was concerned for the lifetime of the very valuable 15hr conversion route. It now appears that since nobody knows what to do, the present route looks like it is just carrying on. I gather the UK CAA is happy to approve the "abbreviated approved course" if it is still 15hrs like at present, with maybe a bit of flexibility. But almost nobody is doing the JAA IR conversion anyway..............