Clue, find out what CASA's definition of an "operator" is and all this will go away.
Duck Pilot,
That's an easy one (you could, of course, look it up) every Australian VH- aircraft has a registered operator, perhaps unsurprisingly it is part of the aircraft registration, and the registered operator is responsible for the operation of the aircraft.
Many moons ago there was Exemption EX38/2004 to CAR 232, but this can no longer be found on the CASA web site (by me, anyway) so it is a reasonable assumption that it has ceased to exist, and I can find no replacement.
If, in fact, this is the case, CAR 232 applies to all operations, and at least two CASA offices think this is the case.
Hence efforts to "nip in the bid" any attempts by CASA recalcitrant to spoil Ausfly, as they did Natfly for RAOz.
Tootle pip!!