Of course - it is better than not complying, but best practice is not a legal requirement.
AINA seem to accept that hire boats are commecial
The AINA definition of a Hire Boat :
‘Hire boat’. A vessel not intended for the carriage of more than twelve persons, offered without a skipper or crew for the sport or pleasure of those on-board, which is not a ‘pleasure vessel’ as defined in the Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 1998, SI 1998, No, 27711 , and that does not proceed to sea.
Within The Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 1998, “pleasure vessel” means- (a) any vessel which at the time it is being used is: (I) (aa) in the case of a vessel wholly owned by an individual or individuals, used only for the sport or pleasure of the owner or the immediate family or friends of the owner; or (bb) in the case of a vessel owned by a body corporate, used only for sport or pleasure and on which the persons on board are employees or officers of the body corporate, or their immediate family or friends.
So, the AINA’s own description of a ‘hire boat’ makes it clear that it is not a pleasure vessel, it is owned by a body corporate.