You actually don't need a permit for commercial work under 4kg where standard rules apply. Anything outside of the standard rules needs a Special Operating Permission. Most of my work is in rural areas so I don't need the SOP. All UAVs however must be registered with the IAA.
Eurousc are dealing direct with the IAA for me to see with additions to my ops manual whether they will accept it to gain SOP. They told me directly that I need to do the full ground school and flight test again. Eurousc and myself think this is misinformation. We'll see. There would be a relaxation of congested area, not sure about the 12 people rule though.