Flight Data Monitoring (FDM), which analyzes FDR data to accomplish things like ensuring that pilots are following SOP's, is a requirement for EASA's Third Country Operators (TCO) certification, however certain (older) aircraft do not seem to require an FDR.
Does this effectively change the requirement so that an FDR must be installed in an aircraft in order to accomplish FDM or is there an exception for FDM as well? I have been unable to find anything specifically addressing this.