2. Except when under training, a person may only act as a pilot if he or she holds a licence and a medical certificate appropriate to the operation to be performed
This does not say that you have to be under training
for a Licence or Rating
I think that, if an Instructor examines your preparation/planning, authorises your flight, supervises the progress of the flight, and debriefs you after the flight, you are, by any reasonable definition of the term, 'under training'.
I believe that, in such a case, the onus would fall on anyone who contested this view to prove their case.
MJ
Ps. In 'EASA Land' there is no such thing as PUT, PuT, Pu/t, or P/ut. only 'Dual'