Governance of Order Book Data: The Cross-Market Order Book Surveillance Mechanism (CMOBS)

Detecting market abuse requires access to high-quality data. In this regard, Suspicious Transaction and Order Reports (STORs) are an important tool for detecting market abuse, and their functioning is subject to ESMA monitoring. However, market operators and NCAs do not have access to a complete picture of market data and, therefore, struggle to detect market abuse schemes that occur across borders. The Listing Act is set to address this limitation by introducing a cross-market order book surveillance (CMOBS) mechanism that will enable supervisors to obtain a more complete picture of the relevant markets. This paper takes stock of these new developments facilitating market abuse detection. Issues to consider include the availability and use of data on connections among persons who might have participated in inside dealing schemes.