Does VFR Operation Require A High Level Of Language Proficiency? It
looks like some in Europe would think it might:

IAOPA WINS LANGUAGE REPRIEVE
(http://www.avweb.com/eletter/archive...ll.html#196325)
The International Aircraft Owners and Pilots Association has
successfully lobbied the International Civil Aviation Organization
(ICAO) to delay by three years implementation of onerous language
proficiency rules it says would severely limit VFR flight in much
of Europe. Under the ICAO proposal, all pilots would require to
demonstrate a high level of proficiency in either English or the
language of the country in which they are flying. In an interview
with AVweb at AOPA Expo in Hartford, IAOPA General Secretary John
Sheehan said the rule makes sense for IFR operations but not for
recreational flyers. "For VFR people it doesn't make any sense,"
Sheehan said. "I don't think [VFR] requires a high level of
[language] proficiency."

Given the US's provision for NORDO VFR operations, that has probably
been in the regulations since their inception, one can only conclude
that VFR operation doesn't even require any communication at all.