"Trade reporting system" according to Article 6(1) of Commission Implementing Regulation (EU) No. 1348/2014 is to be understood as a person who centrally collects and maintains the records of transaction, including orders to trade, of wholesale energy products in order to provide the service of reporting records of transactions to the Agency for the Cooperation of Energy Regulators (ACER), including orders to trade, of wholesale energy products on behalf of market participants.
ACER assumes this requires the trade reporting system to provide the third-party data reporting service as a regular occupation or business that shall treat all information collected in a non-discriminatory fashion and operate and maintain appropriate arrangements to separate different business functions from ancillary third-party services such as trade confirmation, trade matching, bringing together of multiple third party buying and selling interests or clearing services.
For REMIT purposes, it is important to ensure that a level playing field in the post-trade sector is not compromised by a possible natural monopoly in the provision of trade reporting services. Therefore, trade reporting systems are required to provide their reporting services on fair, reasonable and non-discriminatory terms, subject to necessary precautions on data protection.
(ACER's REMIT Q&A point III.3.14)