There is no formal requirement under the Consumer Data Right (CDR) rules for data holders to notify the ACCC that they are sharing Product Reference Data (PRD) prior to 1 October 2020. However, the ACCC strongly encourages data holders that choose to share PRD earlier than their compliance date to inform the ACCC when they do so by emailing email@example.com. We are encouraging data holders to proactively notify the ACCC as it assists with the ACCC’s monitoring of the expansion and uptake of the CDR regime.
It is also recommended that data holders notify the Data Standards Body (DSB), so it can include the data holder’s relevant PRD information in its Product Comparator tool (https://consumerdatastandardsaustralia.github.io/banking-products-comparator/). DSB asks that data holders notify them that their PRD endpoints are live by taking the following steps:
- Raise an issue or pull request on the banking-products-comparator repository to include their PRD APIs in the tool.
- A pull request is preferred. To create a pull request, data holders can create a forked repo using this PR as an example: ConsumerDataStandardsAustralia/banking-products-comparator#22
- The format of the update should be along the lines of:
*Note - for "icon" please ensure it has a transparent background as this ensures the best render possible
CDR Register on-boarding
Data holders are not required to register on the CDR Register until they are required to share CDR consumer data with accredited data recipients in accordance with the timetable set out in Schedule 3 of the CDR Rules.
For the avoidance of doubt, data holders are not currently required to request access to the CDR Participant Portal in order to become Registered to appear on the public CDR Register to share product reference data. There are no other testing requirements for a data holder to satisfy prior to sharing PRD, whether sharing takes place prior to or from the relevant compliance date.
For clarification, Data Holders planning to become an Accredited Data Recipient can request access to the CDR Participant Portal for this purpose. The ACCC will notify Data Holders via the CDR Newsletter when access can be requested for the purpose of registering as a Data Holder.
Impact on swim lane obligations
Choosing to share PRD early does not affect swim lane obligations for other PRD sharing phases or consumer data sharing.
Reporting via the GetMetrics API is delayed until data holders are required to share CDR consumer data.
However, reporting obligations under rule 9.4 will commence for a data holder from the date they begin sharing PRD. The first reporting period for those data holders that choose to share PRD prior to 1 October 2020 will be from the date the data holder starts sharing PRD to 31 December 2020. This report would be due by 30 January 2021.
The ACCC approved reporting form template and guidance for how a data holder can complete their PRD-only reports are available on the ACCC’s website: https://www.accc.gov.au/focus-areas/consumer-data-right-cdr-0/reporting-forms-rule-94.
We also wish to remind data holders choosing to share PRD early that they should ensure they are aware of other obligations that may commence from when they start sharing PRD, including under the CDR rules (specifically Part 2 of the CDR Rules) and Consumer Data Standards.