Their argument is that this approval can only be given to someone with AOC
Well, our ops is not on an AOC and we are approved for RNAV 5 (BR-NAV) and RNAV 1 (P-RNAV) . So are others I know. We have not seeked RNP APPR approval yet.
German reg aircraft & dealt with the LBA. Crews are CBT trained and they required that we have procedures and checked the A/Cs paperwork. No drama IMO as long as the AFM has anything on the capabilities of your avionic...