It would be possible to sell A to A Introductory Flights on a per seat basis and have no AOC / FTO. If Holland is the same as the UK then any organisation that promotes aviation can offer A to A flights up to 90 minutes in duration which can even be flown by a PPL(H) [but they can't be paid].
It's a massive kick in the nuts for AOC holders. Expect FTOs and voucher sellers to start abusing this provision.
Details here:
https://www.caa.co.uk/General-aviati...ctory-flights/