See here for a post on LinkedIn by Harry Nota of Openlink on the topic of surveillance. The post considers the fact that ACER are already collecting on venue data in connection with on venue activity in the EU wholesale energy market, and from April 7th will be collecting off venue and fundamental data. The idea of this is to permit ACER and NRAs (National Regulatory Authorities) to run monitoring tools on the data in order to investigate possible market manipulation.
The post argues that since regulators will be monitoring activity, it may be wise to monitor the same activity internally as well. Although REMIT Article 15 only requires internal monitoring by venues and PPATs (Professional Person Arranging Transactions), that does not mean that such monitoring is not best practice. MAR will also impose additional requirements for some.
Uptake of surveillance systems by market participants has not yet been widespread, but it is possible that this will change in the coming year, once surveillance by regulators starts in earnest.
Energy Risk will be running a morning briefing on the subject, in London on Tuesday 8th December. Full details can be found here.