Yes EASA really screwed us on that one, proves once again that the regulations they make are designed for airline flying not fractional / corporate etc.
The application would not be to the EU commission but to the local CAA. They can give a two month approval/exception for this. If they approve the exception THEY would have to petition the EU commission. But for the rest its about right.
One can only hope that that airtaxi regulations will be more focused on getting a working regulation for our branch.