Absolutely, I think that would probably be helpful.
I think what the commissioner is rightly trying to do is eliminate the problem of corporate directors having to register as independent consultants. There's a whole legal framework that gets dragged into that.
Essentially, what you want to say is that they get treated the same way, under the rules, as employees. Deeming terminology may carry.... I'm not a lawyer. It just jumped out at me that perhaps it could cause problems. In an abundance of caution, I think you've probably hit on something. Maybe come up with another word.