The company that I fly for has been assessed as a complex operator due the number of staff/aircraft (M reg). We have effectively had to comply with the same requirements as an AOC holder, including SMS and FTL scheme. This process has been going on for the last couple of years and has involved employing specialist staff who have liaised with the various authorities. I am not sure how much help we have received from them as it's not my department. A condition of employment for pilots is that they have an EASA licence and medical regardless of any other licences that they may hold.
I understand that smaller operators may have less strenuous regulatory hoops to jump through but that the aircrew licensing rules are the same?
AP