> It's completely routine to see commercial ships running without it
I think this depends a lot on the location, as different areas seems to make it different levels of "mandatory". Are you speaking about the Baltic Sea specifically based on experience?
Yes. I spent a pandemic summer sailing the north sea, denmark, sweden with a friend. We sailed much less in the baltic and I admittedly kind of mix the north & baltic in my memory but they are very similar regulatory environments re boats so it would surprise me if it was common in one but not the other.