Guidance on Future Dated Obligations (FDOs)

Introduction

The following notes on FDOs are gathered from Subject Matter Expert guidance and responses to participant support issues.

API developer portal publication by Data Holder

There is no obligation on the Data Holder to publish an API developer portal as per the CDR legislation or the CDR standards.

However, there is a clear obligation for a Data Holder to present certain experiences such as the CDR Policy and the Data Holder Dashboard.

The distinction between phasing dates and binding dates

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.