The future date obligation date set by ACCC for PRD (Product Reference Data) Phase 2 compliance is 1/2/2021. DSB version 3 PRD APIs are required by 28/2/2021.
One of the key items addressed by version 3 is the introduction of Fee Type “variable”, to be used for Fees that are not fixed, and charged “at cost” by third parties.
At Cost fees are incompatible with version 2 of the standards, and create a scenario where “workaround” to be used within the standards by publishing at cost fees with a $ amount which is incorrect. This could be potentially misleading to the consumer.
As a pragmatic approach, might the ACCC obligation extend the PRD Phase 2 compliance oblication to align with the DSB version 3 PRD APIs obligation. This would allow version 3 to be supported at the end of February.
The ACCC will not change phase 2 Product Rreference Data obligations from 1 February 2021.
As the CDR ecosystem is made up of many different participants, the DSB has deliberately attempted to stagger release dates relative to ACCC compliance dates. The intention is that the compliance dates, that the ADRs rely on for universal availability of a feature, trail the dates stated by the ACCC for DH compliance.
We have found in the past that synchronising changes introduces greater risk for the ecosystem as a whole.
Keeping compliance dates firm also recognises the substantial investment of time and effort required by CDR participants when complying with the Rules,