Distinction between phasing dates and binding dates

Question

The following future dated obligation has a different date for different participants:

Data Holders MUST implement the following data standards effective from 1 February 2022:

Withdrawal: Secondary User Instruction

Why is it documented as a MUST for 1 Feb 2022 for all Data Holders, while non-major ADIs (Authorised Deposit-Taking Institutions) do not have to enable secondary users until November 2022?

Answer

There is a distinction between the obligation dates included in the phasing portion of the rules and binding dates in the standards.

If a specific data holder does not have to implement a portion of scope, due to phasing or an exemption, then the standards for that scope do not apply. It is implicit in the standards, where future dated obligations are expressed, that they apply only to Data Holders that are required by designation and rules to implement the feature for which the obligation is applicable.

See:

• CDS Future Dated Obligations