The intention was for the Regulation to be published in time for it to become effective on 8 April with a 12-month implementation period to allow all RFs to become DTOs by 8 April 2019. Predictably, however, this has not happened - the EC have screwed around with the Opinion from EASA and the UK CAA has gold-plated the result out of all recognition.
The consequence is that, instead of the light-touch regime we were promised, we will eventually get something that is not dissimilar in its requirements to the ATO but with a nominal 5 year oversight schedule to allow the CAA to manage with its current, inadequate bunch of inspectors.