2.105 CP4/23 proposed an implementation date for the Phase 1 simplifications in H2 2024, with firms able to consent to becoming an SDDT at least six months before this date.

2.106 Seven respondents supported the broad proposal for the implementation date. Three respondents commented that firms that can implement sooner than H2 2024 should be allowed to do so. Two respondents raised that due to the gap between when firms will be able to become SDDTs and the simplifications being implemented, non-listed firms with a year-end date that falls between these two implementation dates may have to produce a Pillar 3 disclosure after they are already an SDDT.

2.107 Four respondents were concerned that setting an implementation date in H1 2024 for firms to be able to become SDDTs would mean that firms would have to take the decision on whether to become an SDDT before information on potential capital simplifications would be available and noted it would be hard to decide whether to opt-in until knowing what the proposed capital requirements for SDDTs would be.

2.108 Three respondents noted that ideally all elements of the SDDT regime would be ready for implementation by the Basel 3.1 implementation date, so the PRA should try and expedite its consultation on capital proposals.