IS-BAO & Safety Management Systems
S.F.L.Y, I wish I could sing like him!
I understand safety management and IS-BAO as well as the background to aviation regulation but the intention of the post was a bit of info really.
His Dudeness - the date on ICAO Annex 6 Part II (18 Nov 2010) is that set by ICAO and will have entailed considerable consultation with the signatory states. The question you ask however relates to how EASA and possibly Luftfahrt-Bundesamt (National Aviation Authority of Germany) decides to implement the ICAO rule. As the case with Bermuda shows, they have decided to ratify the requirement with effect from 01 Nov 2009 through the Air Navigation (Overseas Territories) Order.
Sometimes rules become effective early, some on the target date and some have implementation timescales (remember Elementary and Enhanced Mode S) it depends largely on the NAA's of each country.
Best advice is contact LBA (of you NAA if not in Germany) and ask them.