Get a Waiver now.
I believe you still have to get a waiver, but that the process is much more streamlined. The flight doc fills out an online form with all your data that goes to NAMI, and a few days later they email him a waiver. However, I would try to get it ASAP. If you wait until after commissioning or after TBS, what happens if something goes wrong and you don't get the waiver?