The fact is that EU aviation laws have been a disaster in my opinion from the start, and countries generally fail to translate them correctly. That being said I'll stake my money on a statement from a lead Euro Aviation MP who is responsible for these regulations which they agree that the derogation includes all EU countries airspace, and all pilots including the ones that get paid to fly for a living. So we will just have to agree to disagree on NCC and licences, everyone I know states that NCC is not relevant to the type of licence that you hold and it clearly isn't.