The legal obligation to report data to the consolidated tape lies with the data contributors themselves (see Article 22a of MiFIR). While data reporting to the CTP may be outsourced – for example, from a trading venue to an APA, or from one trading venue to another – such outsourcing does not relieve the original data contributor of its legal obligations and accountabilities, including those relating to data quality.
In particular, in the light of such legal obligations, outsourcing of CTP reporting should not introduce artificial latency into the reported data, not be undertaken for the purpose of intentionally restricting the CTP’s choice of transmission protocols or otherwise undermining the CTP’s mission.