4. Budgetary Implications

The initiative is not expected to have any noteworthy impact on the EU budget. The ICT infrastructure to facilitate the exchange among NCAs of cross market order book data for the purpose of market surveillance (CMOBS data) under the MAR is expected to cost around EUR 400 000 in one-off costs, with annual running costs of EUR 200 000. This CMOBS tool would be built by NCAs, potentially as a delegation agreement as allowed by Article 28 of Regulation (EU) No 1095/2010 that can be organised between NCAs and ESMA. Therefore, it would not be funded by EU budget but by NCAs, building on the existing Transaction Reporting Exchange Mechanism system that was established following Directive 2004/39/EC of the European Parliament and of the Council [Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repe

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