Do Data Holders (DHs) need to be sharing all three phases of consumer data before becoming an Accredited Data Recipient (ADR), or just be up-to-date in line with the phasing table?
No, Data Holders do not need to be sharing all three phases of consumer data before becoming an ADR.
However it is important to not that ADIs (Authorised Deposit-taking Institutions), and certain non-ADIs, are subject to reciprocal data holder obligations if accredited prior to the commencement of their requirement to disclose CDR data under the CDR Rules. This affects the timing of their Data Holder obligations as set out in our phasing table.
For all reciprocal data holders, the ACCC has deferred the commencement of reciprocal data holder obligations until 1 March 2021 (Phase 1) and 1 July 2021 (Phase 2 and Phase 3). The ACCC has committed to grant an exemption consistent with this deferred commencement of reciprocal data holder obligations for any ADR falling into this category.