11.I Introduction

The ISD was adopted in 1993 and was the EU framework until the introduction of MiFID I in November 2007. The ISD only marginally covered provisions with respect to the publication and consolidation of equity pre- and post-trade data. National regulation and, where permitted, market forces were in charge of publication and consolidation. In other words, the ISD relied on a national and market-driven approach for the publication and consolidation of equity pre- and post-trade data. During the timeframe of the ISD equity pre- and post-trade data was mainly the domain of RMs. This was the consequence of (1) the optional ISD concentration-rule1 and (2) national rules requiring trading data of ‘off-exchange trading’ to be reported to an RM.2 The following sections therefore emphasize the publication and consolidation approach of RMs. The situation of data vendors under the ISD is also examined.