Multi-crew ops for C421

[Dufo]

If an operators manual requires two pilots for commercial IFR JAR-OPS on this aeroplane, is it necessary for the commander of this crew to hold the ATPL license when logging time as PIC+SIC?
The aeroplane minimum flight crew according to aeroplane flight manual is one pilot and both pilots have CPL+ME/IR + MCC.

(ref. JAR-OPS 1 1.955 & 1.960).

Thanks.

[FLEXJET]

ATPL license (even the written part) is definitely not necessary for this type.

[800m RVR]

The Commander would need a CPL but would also need to fulfill the JAR-OPS requirements for "Commanders holding a CPL" i.e. 700 hrs TT 100 IFR etc, the F/O would just need a CPL.

MCC is not required as that is a JAR-FCL requirement for a multi crew type rating and the C421 is covered by MEP (Land)