I have little detailed knowledge of what ESQCR says
Taking a quick look (IANAL, I may well have missed something(
Many of the regulations in the ESCQR are scoped to generators or distributors, but there seems to be at least one regulation that is scoped explicitly to consumers , and some of the regulations relating to underground and overhead cables seem to be applicable to everyone.
I presume reistard is refering to 8.(4) from the ESQCR
A consumer shall not combine the neutral and protective functions in a single conductor in his consumer’s installation.
The question would then be does using the earth wire to feed an indicator constitute "combining the neutral and protective functions".
"in what sense is it (electrically) 'unsafe'? "
Connecting loads to the Earth conductor can create a couple of potential hazards.
The first is the risk of overloading, since earth conductors are not designed to support normal load currents.
The second is the risk that in the event of the earth becoming disconnected currents flowing in the earth conductor could be diverted into someone touching metalwork connected to the earth conductor. Of course "leakage" currents can also cause this, but leakage impedances are hoepfully somewhat balanced between live and neutral, so the voltage developed on the disconnected conductor would only be half the supply voltage, whereas with a load the voltage developed would be the full supply voltage.
Obviously the first risk is neglitable with a load as tiny as a neon indicator. It would take over a thousand of them to overload the earth conductor in even the smallest size of TP&E. The second though does seem like it could potentially be a real risk.