Will I have to demonstrate compliance with the new Standards for activities planned prior to 2022 but not released or taking place until 2022?
As with any transition to new or revised requirements, we understand that planning for some activities will pre-date the opportunity to implement changes in your organization’s processes. For those activities, (planned in 2021 but taking place or released in 2022), we would not expect to see compliance with the new requirements. Please note that, for those activities, we would expect compliance with applicable aspects of the Standards for Commercial Support and related policies. We encourage you to add a note to the relevant activity files indicating that your organization’s transition to the new Standards was in process, and the planning actions, for example, obtaining disclosures from those in control of content, occurred prior to your organization's full implementation of the new Standards. For activities planned on or after January 1, 2022, you will need to demonstrate compliance with the new Standards.