On September 2, ISDA responded to the public consultation by the European Agency for the Cooperation of Energy Regulators (ACER) Transaction Reporting User Manual (TRUM) and Registered Reporting Mechanism (RRM) Requirements for transaction reporting under the regulation on Energy Market Integrity and Transparency (REMIT) which was launched in early August.

The response addresses the definition of a market participant particularly in the case of clearing flows; the obligations on clearing broker and executing broker as they execute transactions for their clients and on their own behalf; availability of execution data under Markets in Financial instruments directive (MiFID) for the purpose of the REMIT reporting; timeline for implementation and back loading/back reporting of transactions.