As things stand it looks like the answer is Yes. The law has been passed and all member states will need to comply with it within the next year or so. Some pilots who are not dual-rated are holding out for an eleventh hour reprieve to avoid the mass grounding of Third Counrty aircraft. The reality is that it will be pretty easy for EASA licenced crew to dual rate and keep these aircraft flying but it will take considerably longer for Third Country crew to gain EASA licences. If I was flying an N-reg jet for an operator based in Europe I know what I'd be doing right now....
AP