7.II.5 Background

The foregoing illustrates that the ISD post-trade transparency regime for RMs was rather limited. The rules were minimum harmonised and limited in detail. The limited post-trade transparency provisions made the ISD approach bottom-up in nature. Member States and, where permitted by national regulation, RMs had great flexibility with respect to post-trade data publication. The bottom-up approach of the ISD is best understood against the background of the ISD drafting process. At least three elements determined the ISD framework.