That would be my view too, FWIW, because just about every "commercial" activity implied by EASA needs an AOC.
Again I am suprised at the poor language used in these regs. It makes them unenforceable (until some case law is accumulated, and the CAA tries hard to avoid creating precedents, by settling cases on the steps of the court) and will make any higher-end aircraft owner seek some assurance from his insurer. The low-end owners won't get a ruling because they aren't big enough. The other day I spoke to the top man at a top insurer and he said in these circumstances (where not even the CAA can explain what it means) they would pay out.