Does product reference data for all products from all phases need to be made available from 1 October 2020 if you are accredited? i.e. are the product reference data obligations different to mere data holders?
The phasing table states that all product phases must be shared by Accredited ADIs (as reciprocal data holders). Can you confirm that this was indeed the case, or whether the extension on CDR data sharing was extended to PRD?
Correct: PRD for all phases was required to be shared by accredited ADIs from 1 October 2020.
This is reflected in the updated commencement table at Schedule 3, Clause 6.6 of the rules. The table now notes that at the 'start date' (i.e. 23 December 2020, the date on which the most recent rules amendment instrument commenced), accredited ADIs were already required to share PRD for all product phases.
See also our knowledge article on Data Recipient Requirements and Phasing for Product Reference Data: Data Recipient Requirements.