Whilst "many" models carry telemetry it certainly isn't mandatory.
Another case for getting the model flyer on board. Educate him and he may feel disposed to fit telemetry to his model.
The extract from SERA 5005 in the linked report states that
f) Except when necessary for take-off or landing, or except by permission from the competent authority, a VFR flight shall not be flown:
(1) over the congested areas of cities, towns or settlements or over an open-air assembly of persons at a height less than 300 m (1000 ft) above the
highest obstacle within a radius of 600 m from the aircraft;
(2) elsewhere than as specified in (1), at a height less than 150 m (500ft)
above the ground or water, or 150 m (500ft) above the highest obstacle
within a radius of 150 m (500ft) from the aircraft.’
So, given the above, does a PFL down to a height below 500ft qualify as necessary taking off or landing event? I think we can rule out any kind of permission having been granted from the competent authority.