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Yes, that is true, both featured mentioned in the key are not visible here.
Still, the ID can be made on the wing pattern: in caecutiens much darker than in sepulchralis, in caecutiens the outer border of the black belt is convex without appendix at radial vein and an inner basal transparent area is totally or completely lacking.

Moreover, but this is cheating: in June, male caecutiens is common and sepuchralis very rare, more an August species. Plus a garden in Vreden is clearly suited for caecutiens (river !), and clearly not for sepuchralis. The peat bog is 20 km. north at Haaksbergen (indeed, currently the biggest population of sepulchralis by far)

Theo