I do not have my book so I cannot find chapter and section for you but the following what I recall to be correct.
Officers are listed in their type description. They DO NOT need to have a Commander SA to count towards Off Board. Ge3nerally, Individuals have been accepted to fill the role requirements for Off Board. Given the rule-mongers around here, if this was wrong, it would have been found.

HOWEVER, to gain the benefits of Giving Orders, Assume Command, Rally others... they must have one of the following SA's
Unit Commander (ex: Light Infantry Captain)
Divisional Commander (Capitol Major)
Force Commander (Colonel)