Surely an “appropriate civil licence” requires a suitable rating to fly the aircraft?
One gathers that 'appropriate civil licence' will indeed now mean a Part-FCL professional licence, Class 1 medical certificate and Class / Type Rating for the aircraft in question. Hence an EMB-550 TR for the Phenom 100, for example.
Then there's the Ford Prefect. That will require civil pilots to hold an SET Class Rating, rather than the SEP Class Rating required to fly Das Teutor....
But I'm sure that the MFTS snake oil salesmen factored this into their business plan....