Aircraft on AOC operations can have a proviso that the aircraft is flown IAW the Operations Manual. Should it be operated outwith that then it is not insured.
Agreed, but this was a private flight and there may not have been an Ops manual. However, this time next year, there would have been, at least for this size of aircraft, under EASA, Part NCC.
But operators of smaller/lighter aircraft will not be required to have one. I see a loophole in that smaller helicopters are often flown by less experienced pilots, who arguably need one more.