In the early stages of the FAIRsFAIR Project it became clear that the same comments and questions related to the FAIR Principles were being raised by many of those undertaking related work. In March 2020 members of the project prepared a commentary on the ‘baseline’ issues with the FAIR Principles to be used as a common reference point for addressing challenges and monitoring change. Since then there has been a great deal of work around FAIR including the RDA FAIR Data Maturity Model: Specification and Guidelines of indicators designed to support testing against the Principles. This text seeks to consider the issues around the FAIR Data Principles, particularly as they apply to the notion of a Trustworthy Digital Repository (TDR).