I am unclear what the current situation is with EASA, and pax on training flights
The only significant difference is in Part NCO
NCO.OP.180 Simulated situations in flight
(a) The pilot-in-command shall, when carrying passengers or cargo, not simulate:
(1) situations that require the application of abnormal or emergency procedures; or
(2) flight in instrument meteorological conditions (IMC).
(b) Notwithstanding (a), when training flights are conducted by an approved training organisation, such situations may be simulated with student pilots on-board.