So you're suggesting that by fully complying with every applicable EASA regulation is not a sufficient standard to be safe
Safe is not an absolute. The regulations set the overall minimum standard acceptable to the overall society they are in. At the very light end there is deregulation because society says the risk is (almost) entirely yours so bon chance! At the heavier end there is more regulation because society bears more risk for your actions. Biz av and NCC sits somewhere odd in the middle. So if all you are aiming for is being compliant...then you are probably not achieving the safety level your clients expect.