LEI Requirements

There are certain fields within EMIR, MiFIR and SFTR which require populating with an LEI or specifically ‘ISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code’.

All LEIs for these reporting regimes must be valid and included in the GLEIF database.

As a general overview:

  • for new transactions, LEIs for the executing party cannot be lapsed, and must have a status as per GLEIF as “Issued”, “Pending transfer” or “Pending archival”;
  • for the other counterparty within a trade, their LEI is able to be “Lapsed” with GLEIF; and
  • the Initial Registration Date of an LEI must be equal to or after the trade date.

Below are the three regimes and the primary fields which require LEIs to be populated. For each field, details are provided alongside as to whether the entered LEI can be lapsed or not in submission.

The regimes differ in terms of specific validation rules and action types, even though field names may be similar in some cases.

EMIR
FieldUseLEI Validity Rule
Reporting Firm IDFor Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Pending transfer” or “Pending Archival” only.For Action Type “E”, LEI can be any status.
Submitting Entity IDLEI status of “Issued”, “Pending Transfer” or “Pending Archival”.LEI cannot be lapsed in order to submit.
Other Counterparty IDFor Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Lapsed”, “Pending transfer” or “Pending archival” only.LEI is able to be lapsed.
Beneficiary IDFor Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Pending transfer”, “Lapsed’ or “Pending Archival” only.

For Action Type “C’: LEI with status “Issued”, “Pending transfer”, “Pending Archival”, “Lapsed” or “Retired” only.

For Action Type “E”, LEI can be any status.
LEI cannot be lapsed in order to submit, except for Action Type “C” or “E”.
MiFIR
FieldUseLEI Validity Rule
Executing Entity IDThe status of the LEI must be “Issued”, “Pending transfer” or “Pending archival”.LEI cannot be lapsed in order to submit.
Submitting Entity IDLEI of Submitting Entity ID must have a status of “Issued”, “Lapsed”, “Pending Transfer” or “Pending Archival”.LEI is able to be lapsed.
Buyer/Seller IDsThe status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.LEI is able to be lapsed.
Buyer/Seller Decision Maker IDsThe status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.LEI is able to be lapsed.
SFTR
FieldUseLEI Validity Rule
Report submitting entityFor action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Pending transfer” or “Pending Archival”.

For action type “EROR”, LEI can be any status.
LEI cannot be lapsed in order to submit, except for action type “EROR”.
Reporting counterpartyFor action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Pending transfer” or “Pending Archival”.

For action type “ETRM”, LEI can also be “Lapsed” or “Retired”.

For action type “EROR”, LEI can be any status.
LEI cannot be lapsed in order to submit, except for action type “EROR” or “ETRM”.
Entity responsible for the reportThe status of the LEI shall be “Issued”, “Pending transfer” or “Pending archival”.

For action type “ETRM”, LEI can also be “Lapsed” or “Retired”.
LEI cannot be lapsed in order to submit, except for action type “ETRM”.
Other CounterpartyFor action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending Archival”.

For action type “ETRM”, LEI can be “Retired”.

For action type “EROR”, LEI can be any status.
LEI is able to be lapsed.

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